Hazcom training

Reinforcement and practice

How many of us have sat in a classroom and forgotten what was said within days or even hours?

This is why it’s important to reinforce hazcom training from time to time.

“If it’s rarely used, it’s not really remembered,” Levine said.

Reinforcing training or gauging its effectiveness can be as simple as asking employees during informal conversations if they know what chemicals they’re working with, if they know where to find appropriate PPE and other basic questions.

JoAnn Dankert, senior safety consultant at the National Safety Council, said one useful practice is setting up audits or hands-on training. You can have an employee retrieve the SDS for a chemical they use and find pertinent information from it, such as health hazards and PPE.

A supervisor or safety professional also can test whether employees know what to look for on a label and how to get information from it, she said.

Another way to reinforce training, Gioiello noted, is placing – in break rooms or other common areas – posters on subjects such as pictograms or a summary of chemical hazards. Additionally, “lunch and learns” or online options can be part of a multipronged approach.

Most of all, look at what works best for your employees.

“Hazcom training is not one size fits all,” she said.

Keep everyone in the loop

To improve the effectiveness of training, employers have to know what chemicals are coming into their facility and the hazards they pose. That’s why it’s important to maintain lines of communication between departments such as purchasing and/or research and development and EHS personnel, Gioiello said.

“The EHS department doesn’t know there’s a new chemical coming in and they haven’t evaluated it into their training methodology,” she said. “That conversation is huge.”

Another issue in terms of information sharing, Dankert said, is within multiemployer worksites.

In such cases, it’s a shared responsibility, according to OSHA. For example, if a temp agency sends workers to a facility, OSHA says the temp agency is “expected to provide generic hazard training and information,” such as categories of chemicals that an employee might encounter. That training must be completed before the temporary employee begins work on a project, OSHA says in a Temporary Worker Initiative bulletin on hazcom.

“The staffing agency also has a duty to inquire and verify the host employer has adequately fulfilled its shared training responsibilities for assigned employees,” the bulletin states. “To ensure the host employer provides appropriate and sufficient information and training regarding hazardous chemicals, the staffing agency should be-come familiar with the hazards at the host employer’s worksite.”

To accomplish that, OSHA says, staffing agencies can review a host employer’s hazcom program and training, or perform a walkthrough of the worksite. They also should maintain communication with employees and the host employer, who is responsible for “site-specific” hazard training.

Be ready for changes

On Feb. 16, OSHA published a proposed rule that would update its Hazard Communication regulations to align with the seventh version of the United Nations’ Globally Harmonized System of Classification and Labeling of Chemicals, also known as GHS. The proposed rule features no changes to 1910.1200(h) from the current training regulations, which align with the third version of GHS. However, new subjects may need to be added to training.

Among the proposed changes are updates to health hazards (Appendix A) and expansion of certain physical hazard categories (Appendix B), such as aerosols and flammable gases. Others include a new chapter in Appendix B on desensitized explosives, along with changes to labeling and two sections of SDSs.

OSHA contends that the goal, as with other updates, is to increase worker protections and reduce the incidence of chemical-related occupational illnesses and injuries.

“Companies training people on the chemicals they’re working with and making sure they can handle them safely means that we have safer workers, safer families and safer communities,” Gioiello said. “Everyone is just better off.”