OSHA asked for comments on its Process Safety Management standard, potential changes to PSM enforcement policies, and potential updates to its Explosives and Blasting Agents, Flammable Liquids and Spray Finishing standards.

GHS: Perception vs. Reality

Here's what OSHA's Dec. 1, 2013, training deadline should mean to you.

I was having a conversation recently with the safety officer of a large health care facility about the looming Dec. 1, 2013, training deadline established by OSHA. The new training requirement mandates that employers provide employee training on the new GHS Safety Data Sheets (SDSs) labels, pictograms, etc. that will be available from chemical distributors during the next couple of years. I was astounded to hear him express how nervous he was that he would not be able to accomplish this task for his 4,000-plus employees by the deadline and by his perception that he would be in big trouble with OSHA.

You can be assured this was not an isolated incident, because the fact of the matter is the majority of safety officers I have spoken to in recent months shared the same concern regarding their perception that OSHA is going to visit them with a big fine if they didn't meet this training deadline. Talk about the power of suggestion and a great example of perception versus reality!

In jest, I told him that I was certain OSHA had a list of companies that its officers were planning to visit beginning on Dec. 2 to check on their training results, and his hospital was at the top of the list. The reality is, we are now in January 2014, and I doubt that anyone reading this article was visited by OSHA in the past few weeks and fined for not completing HazCom 2012 training on time.

I am not in any way attempting to make light of this important topic or the training requirement established by OSHA, but don't you think it is time for a little practical thinking here? Consider this: Millions of dollars have been spent in recent months by companies like yours in an attempt to meet their compliance obligations, with little thought about what the final outcome would be. For example, the new SDSs, labels, pictograms, and hazard and precautionary statements will not even be available in many cases from suppliers until 2015, so the reality is this training will need to be conducted numerous times during the next few years unless your employees have photographic memories.

The new SDSs and other GHS elements recently adopted by OSHA were intended to provide information in a manner that employees using hazardous chemicals could comprehend, thereby reducing the rate of chemical-related accidents and illnesses. The reality is that a significant number of our nation's employees comprehend at or below a ninth grade level, and the new SDS will continue to be technical and confusing to those employees and most of the other audiences for which they were intended. To make matters even worse, many of the SDSs recently reviewed by my company have increased in length by as much as 200 percent; just imagine how much technical data employees now will have to sift through. The reality is, it is hard to imagine how these new SDSs will have any effect on lowering the accident and illness rates in the workplace.

Many of you reading this today who have made a diligent effort to meet this training deadline may want to take exception to my observations, and I certainly can understand your frustration. The reality is that the majority of safety professionals I speak to every day freely admit that (for a variety of reasons) most of their employees never read an MSDS, so how will we ensure worker comprehension will be increased as stated by OSHA by the introduction of these new SDSs and other GHS elements?

What we all secretly hope is that our employees will never have an incident and that we will never be implicated for not providing meaningful information and training. If we could wave our magic wand, we would wish that our employees take responsibility for their own safety, thus removing the stress from us.

The perception is that, because our employees don't use large drums, vats, or tanks of chemicals, they must not be exposed in a manner sufficient enough to warrant any major concern. In other words, if an employee isn't bleeding and doesn't have any bone protruding through the skin, everything must be okay.

But the reality is that many workplace chemicals, even those small amounts contained in some aerosols, can and do have serious adverse health effects. You only have to read a few of the articles on the American Lung Association's website to see just how serious this issue is. Many statistics reveal that upper respiratory diseases such as asthma are increasing at alarming rates; if this were not true, then why do we even have a Hazard Communication Standard?

Paying Attention to the Real Training Issue
What is amazing is the amount of emphasis that was placed on providing employee training on the new OSHA elements by Dec. 1 and how little attention has been given to the real training issue. As stated by OSHA in Paragraph (h) of the Hazard Communication Standard, employers must provide effective information and training for every employee using chemicals. Paragraph (h) of the HCS addresses employee information and training:

"First, employers should provide employees with effective information and training on hazardous chemicals in their work areas at the time of their initial assignment and whenever a new physical or health hazard that employees have not been previously trained about is introduced into their work area. Information and training may be designed to cover categories of hazards (such as flammability or carcinogenicity) or specific chemicals."

So once again, looking at perception versus reality, we perceive or assume that if we provide access to a SDS, instruct employees on the new format, and show them a video about the new changes, somehow they will be able to work more safely with chemicals and we have now met our obligation as safety professionals. The reality is that we should be able to demonstrate that our employees understand the hazards they are exposed to and what measures they can take to protect themselves from being exposed. Anything short of this reality is akin to Dorothy clicking her red shoes together and ending up in Kansas.

OSHA stated in the early Hazard Communication Standard that “For any safety and health program, success depends on commitment at every level of the organization. This is particularly true for hazard communication, where success requires a change in behavior” -- and this statement remains true today. Have you ever considered just how much money and time you and your staff have spent over the years generating chemical lists, collecting data, and paying for services, all in an attempt to simply comply with the letter of the rule? Though it may make you feel better, simply providing SDS information or making it available to employees does not satisfy your compliance obligation.

If you are going to spend the time gathering this information and making a list, why not make it productive? Divide your list up by department and, in addition to the chemical name, add the following components to your list:

  • The physical and health hazards of each chemical
  • The target organs that could be affected
  • The route of exposure (how the chemicals get into the body)
  • Personal protective equipment

Develop your training programs to help your employees understand why this information is important and focus especially on the target organs and how exposure to certain chemicals can permanently damage these organs. For example, if a product contains an ingredient that is a reproductive toxin, you would want to point out, especially to the younger employees, how this could affect their chance of having children in the future.

If you focus on the chemicals in each department rather than as a whole, your training program will be much more effective and meaningful. Unless the hazards are identified prior to an employee’s work with a chemical, a company is only addressing the letter of the law and not the spirit of the law.

There are numerous examples and resources available to you. Although they may require a little research and time in the beginning, in the end you may finally reduce the gap between perception and reality.

This article originally appeared in the January 2014 issue of Occupational Health & Safety.

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