Why Effective Chemical Safety Training Is More Important Than Ever
Despite being a critical component of employee safety, HazCom training is one of the most overlooked elements of employer safety programs.
- By Phil N. Molé
- Aug 01, 2020
Despite being a critical component of employee safety, HazCom training is one of the most overlooked elements of employer safety programs. And now, the recent global COVID-19 pandemic has presented several new challenges to millions of workplaces, as an increasing number of chemical disinfectants are being introduced into workplaces, creating a critical need for additional chemical safety training.
For instance, OSHA’s Hazard Communication Standard (HCS) does not require employers to include consumer cleaning products in their workplace HazCom program when those products are used as intended by the manufacturer. However, those same products when used in a different manner, including in greater quantities, durations or frequencies that result in a range of exposures greater than that experienced by typical consumers, can be subject to the stricter requirements of the HCS.
Today, COVID-19 has created an urgent need for more frequent disinfectant use for cleaning potentially contaminated surfaces and limiting the further spread of the SARS CoV-2 virus. As a result, workplace exposures may now exceed the range of the typical consumer, triggering coverage under OSHA’s HCS.
The five key components to OSHA’s HCS and high-level employer responsibilities are:
1. Maintain a Written HazCom Plan
2. Keep an updated written chemical inventory
3. Ensure proper labeling of hazardous chemicals
4. Maintain and provide access to safety data sheets (SDSs)
5. Train employees on HazCom and chemical hazards
As one of the main pillars of HCS, employee training is critical not just for workplace safety, but for your company’s overall regulatory compliance. While OSHA doesn’t expect workers to be able to recall and recite all the data provided about each hazardous chemical in the workplace, effective training ensures employees are aware that they are exposed to hazardous chemicals, know how to protect themselves from those hazards – including how to detect releases of those chemicals—and where to get specific hazard information (e.g., from SDSs).
And in addition to making sure employees have access to the corresponding SDS for any new chemical disinfectant introduced to the workplace when use of that product extends beyond that intended by the consumer product manufacturer, employers must also pay special attention to the dangers that result from the misuse or mixing of these chemicals with others in use or present at your workplace, and ensure the proper safeguards and training is in place.
Following is a deeper look at how to make chemical safety training effective, engaging and relevant so your employees are getting the most from it.
Building an Effective HazCom Framework
When it comes to HazCom training, OSHA requires employers to train people on the hazardous chemicals in their work areas, which can be achieved through training on specific chemical products or types of chemicals (such as acids, bases or flammables). Employers are also required to train on the details of the Written HazCom Plan, which must explain how SDSs are managed and ways to access them. Additionally, your employees should be able to read and understand the SDSs and corresponding container labels—both the shipped and workplace/secondary labels. Outside of these parameters, OSHA gives a significant amount of bandwidth to employers to determine how they deliver training and ensure that it’s effective.
An effective chemical safety training program should include:
The HazCom standard basics. Employers are required to train on HazCom in general. An important fact that employees should know is that chemical manufacturers are required to provide SDSs and shipped container labels for products shipped to downstream users, and those downstream users (employers) must provide information about the hazards of the chemicals in their workplace to employees before they come into contact with them.
Hazard communication program details. OSHA expects employees to understand the details within your company’s Written HazCom Plan, including, but not limited to the specific SDS and label management practices for the chemicals at your facility. A key factor here is ensuring that you’re updating both your Written HazCom Plan and training to reflect any changes to your chemical management system.
Physical and health hazards of chemicals in the workplace. If the hazard is present in your facility, training must cover it. This includes those from simple asphyxiants, combustible dusts and pyrophoric gases, as well any hazards not otherwise classified.
How to detect the presence or release of chemicals. Whether done through use of monitoring equipment or simple observations, like odors or visible evidence of sheens or stains, employees must know how to detect a chemical release. If digital monitors are used, include information about where they are, what they measure, and how to interpret the readings. And make sure the methods discussed for detecting the presence or release of chemicals lines up with the specific chemicals and hazards you have at your facility.
Guidance on the storage and disposal of chemicals. Safe use of a product includes ensuring chemicals are returned to storage in the appropriate manner, using the proper equipment. Similarly, the cleanup and disposal of chemicals is often overlooked, creating hazardous conditions both for employee safety.
Hazardous chemical protection. This includes clear and detailed information on the usage of personal protective equipment (PPE), safe work practices, engineering controls and any other specific procedures or controls you’ve implemented.
Training is only effective if employees receive it. While many employers do a good job of providing the right training content, they often fall short in identifying all the workers who require training. OSHA has stated that it intentionally kept the scope of who requires training broad in its Hazard Communication Guidelines for Compliance document, saying this “includes any situation where a chemical is present in such a way that employees may be exposed under normal conditions of use or in a foreseeable emergency.”
For some employers, this could mean that training is needed for all your employees, while for others it may only include a select group. Overall, it’s important to be familiar with your operations, the job tasks involved, the associated chemicals, and the possible routes of exposure when determining which employees require training.
One important tip is to pay attention to Section 7 of the SDS, which includes information about everyday storage and usage (mentioned above), including incompatible chemicals to avoid. Many cleaning and disinfecting chemicals are incompatible with others, and because of recent disinfectant shortages people may consider using some chemicals at the same time or blending them together, which makes it essential for your workers understand how to avoid inadvertent, dangerous chemical reactions.
A quick example is mixing acids with bases. Common cleaning products that include acids are hard water/mineral deposit removers, toilet bowl cleaners, rust removers, tub and tile cleaners, mold removers and vinegar. Some common cleaning products that include bases include bleach and bleach-containing products, glass and all-purpose cleaners (which often contain ammonia), drain cleaners, laundry detergents and baking soda.
Making Training Engaging
HazCom training must be delivered in a language and method that employees understand. The true test of whether training has been effective or not is whether they can put that training to use in the workplace. Employers who conduct training simply for the sake of completing the task, with little regard of whether the information is being retained, will have a difficult time convincing an OSHA inspector that they’ve met their HCS training requirements.
This is an area where today’s on-demand, online training solutions are useful. Feedback VelocityEHS has received from thousands of safety professionals is that the move these days is to training software that offers an extensive library of flexible online courses with content that is interactive and engaging. Shorter, more digestible training courses are particularly appealing to younger workers, while multi-language options help ensure all employees understand the information being conveyed.
Especially in today’s climate, employers are looking to free employees from a centralized classroom environment and provide workers access to courses from remote locations where they learn at their own pace.
A complete learning management system (LMS) is a flexible and intuitive system for managing e-learning assignments, training content, and all of workplace training program activities—including virtual classroom (distance learning) sessions and in-person classroom training activities—across the entire organization through a centralized cloud-based system. Best of all, these systems give you the agility to complete your training in the physical workplace or remotely, which is even more important in uncertain times like these.
Look for a solution that can turn existing PowerPoint presentations into fully interactive e-learning courses or allows you to import content from a wide selection of third-party content providers for easier program management. The best systems even provide updated COVID-19 training content to ensure employees understand newer risks they encounter in the workplace.
Keeping Training Relevant & Enjoyable
While most employees understand the necessities of training, it is often not something they look forward to, which creates an additional barrier for employers to overcome.
Employees respond better to HazCom training material when they understand the reasoning behind it. Ensure your training demonstrates the real-life implications of what is being taught. And continue that training out on the floor. Test your people on the course elements on-the-fly in the actual settings where they would need to know the information quickly. This will give workers the chance to showcase how the lesson applies to their actual work tasks, and further reinforces why it’s so important to retain the information being conveyed.
Another way to make training relevant is by adjusting the quality of your training objectives. If your objectives are too vague, you won’t know whether you’ve met them or not. Challenge yourself to create specific objectives, with performance conditions spelled out that you can test against, so you know when your training is hitting the mark and can quickly fix problems when it’s not.
Worker Training for the “New Normal”
The need for dynamic HazCom training has never been greater. Traditional course lesson methods involving text-heavy presentations and stand-up lecturing can have a hard time connecting with a diverse and technologically advanced workforce. As you adjust your HazCom training to the real-world conditions we are operating under, be sure to look for solutions that are interactive, participative and engaging so that your training helps your people meet the challenges of a changing world.
This article originally appeared in the August 2020 issue of Occupational Health & Safety.