Keeping the FUN in FUNdamentals
Try out these methods to make your hazard communication training fun and informative for employees.
If we look at all of the OSHA citations issued from October 2009 through September 2010 for all industries, the Hazard Communication Standard (29 CFR 1910.1200) is the third highest, and it's number one for general industry.
HazCom has been around since 1983 for manufacturing and has been in the top five for the number of citations issued for almost these past 27 years.
Let me ask you, "How often do your need to give HazCom training to your employees?" Is it monthly, yearly, every two years?
I know that many of you do annual training to keep your employees entertained. (Yes, entertained --more about that later.) It is a tough job.
OSHA doesn't say that we have to do annual training. The regulations, at 1910.1200(h)(1), say: "Employers shall provide employees with effective information and training on hazardous chemicals in their work area at the time of their initial assignment, and whenever a new physical or health hazard the employees have not previously been trained about is introduced into their work area." And we can do training that covers "categories of hazards (e.g., flammability, carcinogenicity) or specific chemicals."
So how are you going to keep the FUN in the fundamentals to make it interesting to your employees? Let's try an experiment. Get a sheet of paper and number it from one to five. As you read these questions, write down the first thing that comes to your mind . . . don't hesitate.
Five Easy Questions
- What is your favorite color?
- Name a piece of furniture?
- Name a flower?
- Pick a number from 1 to 4?
- Name an animal in the zoo?
Done. Now, check your answers with those that I've listed at the end of this article (Q-1). How many of yours matched mine? If you are like most people, you got four or five out of five correct. Why? It's because of human nature. As humans, we tend to conform to what is common and what is easy. Your employees will be doing the same.
When you give them training, make it fun and interesting. Make it different and make it memorable. Here are some suggestions on how to do it.
Material Safety Data Sheets
The MSDS is one of the two prime documents in conveying hazard information from the manufacturer (or distributor) to the end user. What's the other? (see the Q-2 answer at the end of this article). OSHA did the regulated community a disservice when it did not specify the format for an MSDS, but that will be changing when the Globally Harmonized System (GHS) comes into effect. For now, we have the eight sections to discuss with employees. What can we do to make it fun?
Give them the MSDS for an unknown. Have you ever looked at the ingredients for some food items? For example, if you had an MSDS that included the following ingredients, what is it? (see Q-3)
- Carbonated water
- High fructose corn syrup
- Caramel color
- Phosphoric acid
- Natural flavors
Another exercise I like to use to help employees understand what information is in an MSDS and what it means is to change an MSDS for a common chemical into the MSDS for an unknown chemical. I then have the employees read it. As they do, I encourage them to call out what they think the chemical is. I put those names on a flip chart. It is a brainstorming session; I don't criticize or allow other employees to criticize or comment. At this point, all answers are viable.
We then go through the MSDS section by section, and I will read a line from the section to see whether we can use that information to eliminate chemicals until we are left with only one chemical (the correct one, I hope). Here is a link to a copy of the MSDS that I use.
Do your employees really understand some of the chemical reactions that they perform every day when they mix 2,4-dinitro, short-chain with 4,5,6-trimethyl, long-chain to get "Wonder Goop®," your finished product? It is not always safe to do some of these reactions in the open, but there are others that are safe that you can do. For example, what happens when you mix baking soda (sodium bicarbonate) with vinegar? They react and react violently, giving off carbon dioxide that causes the liquid to foam up. If you demonstrate this, cover your table top with plastic and have absorbent materials handy. What other similar types of reactions can you do? (see Q-4)
Many of OSHA's standards talk about showing that the employee understands the subject or is competent in the subject. How are you going to do that? You need to test them.
Call it what you will -- test, quiz, memory exercise, tryout, or examination -- it needs to be done, but it does not have to be in writing. Orally answering questions is a way to test employees. Having them demonstrate selecting the correct respirator to use for 4,5,6-trimethyl, long-chain when being exposed above its Permissible Exposure Limit is another way.
So far in this article, I've given you four quiz questions, and I hope they have been enjoyable. Here's another quiz: Is this label correct for the chemical?
4, 5, 6-triméthyl, à longue chaîne
John's de la Chambre des produits chimiques
111, rue de fleurs
Odeur eh bien, France
You can find the answer at Q-5 at the end of this article.
Speaking of labels, I found bottles containing waste oil during an inspection in a maintenance shop. The bottles were not properly handled for disposal, let alone labeling. Which brings up the visual aspect: Photograph problem scenes in the workplace and ask employees why they are wrong. Then show them the correct image.
Physical properties of chemicals may be a hard concept for non-technical people to understand. Here's a little exercise that might help.
I show some photos of common items around the house, such as bleach, milk, orange juice, vegetable oil, rubbing alcohol, salt, and toothpaste. I then ask the audience to think about these chemicals in their homes. I emphasize the word chemical for these common ingredients. I then ask them to fill in the table with the color, odor, physical state, and pH for each of the items, based on what they think it is. (A blank copy of that form is linked here.)
I then pour some of the ingredients into a jar and we look at it, have them test the pH, determine the physical state, odor (yes, I caution them about smelling chemicals), and color. I finish up by asking them, "Will it burn? Will the vapors coming out of the bottle burn?" That allows me to have a discussion about flammability and fire properties.
Another Hazardous Chemical
Let me leave you now with some information about one of the most hazardous chemicals in common usage. This chemical is so common that we have babies dying if they fall into containers of this chemical. Unfortunately, it is odorless and colorless. It is also found mixed with a number of other hazardous chemicals so they are caustic, explosive, and poisonous compounds. Some of the hazards include:
- Death due to accidental inhalation of DHMO, even in small quantities.
- Prolonged exposure to solid DHMO causes severe tissue damage.
- Excessive ingestion produces a number of unpleasant though not typically life-threatening side effects.
- DHMO is a major component of acid rain.
- Gaseous DHMO can cause severe burns.
- DHMO contributes to soil erosion.
- It leads to corrosion and oxidation of many metals.
- It contaminates electrical systems and can cause short-circuits.
This chemical is Dihydrogen Monoxide (DHMO). Some synonyms include Dihydrogen Oxide, Hydrogen Hydroxide, Hydronium Hydroxide, and simply Hydric Acid. (Q-6)
Q-1. Five Easy Questions
- What is your favorite color? -- Red
- Name a piece of furniture? -- Chair
- Name a flower? -- Rose
- Pick a number from 1 to 4? -- 3
- Name an animal in the zoo? -- Lion
Q-2. Labels are the second form of communication to the employees.
Q-4. Mentos® and Diet Coke®. Do this outside, this does make a mess. This was shown on MythBusters on the Discovery Channel.
Q-5. No. The label needs to be in English, and OSHA requires that labels contain the following:
- 1910.1200(f)(1)(i) -- Identity of the hazardous chemical(s);
- 1910.1200(f)(1)(ii) -- Appropriate hazard warnings; and
- 1910.1200(f)(1)(iii) -- Name and address of the chemical manufacturer, importer, or other responsible party.
The English label would be this:
John’s House of Chemicals
111 Flower Street
Smell Well, France
Q-6. Dihydrogen Monoxide's chemical formula is H20, CAS # 7732-18-5, or better known as water.
Maddie Carroll, a safety officer in Winnipeg, Canada (e-mail: firstname.lastname@example.org) sent me two safety folk tunes that she uses in her training: the WHMIS Warble and the HAZCOM Song.
This article originally appeared in the May 2011 issue of Occupational Health & Safety.
Barry R. Weissman is a Registered Environmental Manager, a Certified Safety Professional, a Certified Hazardous Materials Manager, and a Fellow of the Institute of Hazardous Materials Managers. He is Certified in Homeland Security at Advanced Level 5 and is a Certified Infrastructure Preparedness Specialist.
Barry is a frequent contributor to various safety magazines and online forums and co-author of the chapter on Hazardous Wastes in the ASSE Safety Professionals Handbook. He is a speaker at various national safety, hazardous materials and homeland security conferences. In addition, he is the moderator of RegulatoryPost, a Yahoo! Group providing regulatory updates, safety tips and links to training materials. You can subscribe to RegulatoryPost by sending a blank email to: RegulatoryPostemail@example.com.