Three Quick Steps to Better HazCom Training
High-level considerations can go a long way to improving your facility’s effectiveness.
- By Phil N. Molé
- Aug 01, 2022
When I worked as a regulatory consultant, I conducted many site visits to evaluate companies for compliance with OSHA’s HazCom Standard. During many of those visits, I’d identify a disconnect. The facility’s management would have many of the right program elements in place, like a mostly complete library of safety data sheets (SDSs) and chemical inventory list, a written HazCom Plan (although not usually site-specific or detailed enough), and an obvious effort to make sure all hazardous chemical containers are labeled. But on the plant floor, when I’d ask an employee how they’d access an SDS, or who they could go to for more information about HazCom management practices, I’d get lots of blank stares and shoulder shrugs in response. The causes of that disconnect were problems in the facility’s HazCom training practices.
Luckily, there are a few high-level considerations that can go a long way toward improving your training’s effectiveness. There are three simple steps you can take to build and maintain a HazCom training program that works.
Train All Employees Who Need It
The first step is to determine which of your employees need HazCom training. Some employers miss this part, because they’re so set on getting the training done, but don’t put enough thought into identifying all employees who need it.
But how do we know which employees need training? It comes down to determining which employees may be exposed to hazardous chemicals at work, because 1910.1200 (b)(2) states that the HazCom Standard’s scope applies “to any chemical which is known to be present in the workplace in such a manner that employees may be exposed under normal conditions of use or in a foreseeable emergency.” In letters of interpretation, OSHA clarified that “foreseeable emergency” would include equipment failure, rupture of containers, or failure of control equipment, all of which could result in an uncontrolled release.
This is a broad scope, and for some employers, it may mean that they need to train all employees, including the temporary and contracted workers at their work locations. You’ll need to make the best decision possible based on familiarity with your operations, the job tasks involved, the associated chemicals, foreseeable emergencies and the possible routes of exposure. Consulting your employees and involving them in this process is a good way to improve the amount and quality of information available.
Include the Right Things in Your Training
Now that you’ve selected the right employees to train, you need to select the right content to include in your training. According to the Standard, your HazCom training needs to cover:
- “The requirements of this section,” as OSHA puts it in 1910.1200 (h)(2)(i). In OSHA guidance documents, such as the Small Entity Compliance Guide for Employers That Use Hazardous Chemicals, OSHA elaborates that training must cover “the general requirements of the Hazard Communication Standard.”
- Safety data sheets (SDSs) and labels (manufacturer shipped labels and workplace labels) and how to read, use and understand the information, including the order of information on an SDS.
- Ways of detecting the presence or release of chemicals, whether through the use of monitoring equipment or simple observations. If you use digital monitors, talk about where they are, what they measure and how to interpret the readings. Make sure that the methods discussed here align with the specific chemicals and hazards at your facility.
- The physical and health hazards of chemicals in your workplace, as well as any hazards not otherwise classified. The standard gives you the flexibility to either train your employees on all the individual chemicals they may be exposed to, or to group your chemicals by hazard classes and categories and train on those. Do what makes the most sense for your workplace. Just remember that if the hazard is present in your facility, you need to cover it in training.
- How employees can protect themselves from chemical hazards, including the use of PPE, safe work practices, engineering controls and any other specific procedures or controls you’ve implemented. It’s important for both the safety of your workplace and the compliance of your training program that you have some form of exposure control identified for all of the specific hazards present in your facility. Be clear and detailed enough to eliminate any potential confusion.
- Details of your Hazard Communication Program, including how you manage SDSs and shipped labels, your facility’s chemical inventory, methods for accessing SDSs at your facility, the details of your workplace labeling system, how to properly store chemicals, what to do in the event of chemical emergencies, who to seek out for more information, how/where to access the written plan and any other details you believe are important for effective HazCom management. Since your training program and written HazCom plan are complementary pieces of your chemical management system, any changes or updates to one will likely necessitate changes to the other.
Review and Update Your Training Program
You won’t be able to maintain an effective HazCom training program unless you’re verifying your training’s effectiveness, documenting your training, and then using that information to revise your training program.
On OSHA’s landing page for its 2012 final rule that updated HazCom Standard to align with Revision 3 of the UN’s Globally Harmonized System of Classification and Labelling of Chemicals (GHS), the Administration made it clear that it was moving from giving workers the “right to know” to giving them the “right to understand.” In other words, the test that you’re meeting your regulatory obligations as an employer isn’t that you’ve done the training; it’s that your employees understand the training. The standard also specifically states that you must train in a manner and language your employees understand. Training & Learning software can help you more easily and effectively meet your training needs by giving you the ability to deliver engaging eLearning courses in the languages spoken in your workplace, and by offering employees the ability to complete training at their own pace.
What does that mean in practice? While OSHA doesn’t expect that workers are able to recall and recite all data provided about each hazardous chemical in the workplace, they want workers to understand that they are exposed to hazardous chemicals, know how to read labels and SDSs, have a general understanding of what information is provided in these documents and how to access them.
And while documentation of training is not the benchmark for compliance, it’s still important because without good documentation you’ll lack the information you need to assess if your training was effective. OSHA advises that your training documentation should include the training date, learning objectives and outline of training content, the names of trainees (by employee identification number or social security number), the names of instructors and any objective data (e.g., test results) demonstrating that employees understood the training.
Of course, the key is to actually use the feedback you’re getting to improve training. For example, if you’re either seeing in person, or via review of test results, that many employees don’t seem to understand your site-specific process for accessing copies of SDSs, you know you need to address that—and sooner rather than later, given the importance of that knowledge to everyday safety. The right level of documentation also helps you determine when you’ll need to revise content to account for major changes to your HazCom practices, such as introduction of a new chemical hazard class to the workplace, or replacement of a physical SDS library in binders with a cloud-based software system.
Keeping HazCom Training in Perspective
Let’s wrap up by focusing on the big picture, because that might give us the perspective we need to improve our HazCom training.
Before the HazCom Standard existed, fatalities and illnesses from occupational chemical exposures were far more common because employees lacked information about the hazards of the chemicals in their workplace and about the equipment and practices needed to store and use them safely. The underlying purpose of the HazCom Standard, in the words of one of OSHA’s HazCom guidance documents, is “to reduce the incidence of chemical source illnesses and injuries.”5 And one of the most important ways to accomplish that is by providing employees with the information and training they need to work with chemicals as safely as possible.
The key takeaway I’d offer here is not to see your training program as a “box checking” exercise needed to meet a regulatory requirement. Instead, see your training as what it is: a central part of your active commitment and responsibility as an employer to provide all of your employees with a safe workplace.
By following the three simple steps outlined in this article, you can build and maintain the kind of HazCom training program that you’d want if you were in your employees’ shoes. It’s training focused on outcomes that’s flexible enough to meet the needs of your entire workforce, and that has the commitment to continuous improvement needed to make your workplace safer and more sustainable.
This article originally appeared in the July/August 2022 issue of Occupational Health & Safety.