To protect employees and reduce the occurrence of illnesses and injuries, employers need information about the dangers of the chemicals they use and recommended protective measures. Workers have both a right and a need to know this information to take steps to protect themselves when necessary. That’s why training’s key.
Perhaps it’s no surprise that hazard communication tops the list of most-cited OSHA violations. And that’s tough on businesses. Sliding out of OHSA’s good graces costs companies millions annually, between fines, legal fees, and internal time and effort.
OSHA’s Hazard Communication standard (29 CFR 1910.1200) details the chemical hazard information that employers need to share with employees. And within that, paragraph (h) covers employee information and training.
Employers must train employees on the hazardous chemicals in their work area before initial assignment and when new hazards are introduced. It’s critical that workers understand they are exposed to hazardous chemicals, know how to read labels and SDSs, have a general understanding of the information provided, and know how to access related tools.
Employees must also be aware of the protective measures available to them, how to use or implement these measures, and whom to contact if an issue arises.
What OSHA Looks for:
- OSHA Safety and Health Officers will talk to employees to determine if they know they are exposed to hazardous chemicals, have received training, and know where to obtain information on labels and SDSs.
- The standard does not require employers to maintain employee training records, but many employers choose to and wisely so. Keeping records will help monitor the program to ensure that all employees are appropriately trained. It also makes demonstrating compliance a breeze.
The HCS standard requires you to inform employees of:
- The general requirements of the Hazard Communication Standard (HCS)
- Where hazardous chemicals are located (plus operations where exposure may occur)
- What the workplace hazard communication program includes, and where/how they can access the program
Here’s what your training needs to cover to comply with the Hazard Communication Standard
Training is an active process. To comply with the HCS your training must address the following:
- Methods and observations used to detect the presence or release of a hazardous chemical in the work area (e.g., monitoring conducted by the employer, continuous monitoring devices, visual appearance or odor of hazardous chemicals, etc.)
- Physical, health, simple asphyxiation, combustible dust, and pyrophoric gas hazards, as well as hazards not otherwise classified, of the chemicals in the work area
- The measures employees can take to protect themselves such as appropriate work practices, emergency procedures, and the use of personal protective equipment (PPE)
- Details of your hazard communication program, including an explanation of the labels received on shipped containers and the workplace labeling system used by their employer; the SDS, including the format of the SDS (where each type of information is located); and how employees can obtain and use the appropriate hazard information
A properly conducted training program will ensure worker comprehension and understanding. It’s not sufficient to just read material to the workers or simply hand them material to read.
How KPA Helps Strengthen Your Hazard Communication Program
KPA is here to help you maintain a comprehensive Hazard Communication program.
HazCom Written Program
KPA’s expert EHS consultants will help you develop a written program that is tailored to your business. It will include everything OSHA looks for including:
- A list of all the chemicals present in your workplace
- How and where employees can access Safety Data Sheets
- Identify the individual designated as responsible for the oversight of your program
Hazard Communication Awareness Training
KPA also provides online and on-site Hazard Communication training. Courses for both employees and managers cover how information about hazardous materials is communicated in the workplace. They also include information about how to read hazard labels and safety data sheets as well as the importance of the written program and training.
SDS Management
Ensuring your employees have quick and easy access to Safety Data Sheets may be the most important component of your Hazard Communication program. With KPA EHS you have access to a database of over 70 million datasheets. You can create your own SDS folders and custom SDS library with an easy to search interface. You’ll also have offline access and hardcopies to ensure all your staff can easily find SDSs. Finally, you can print pre-populated secondary container labels for GHS compliance.
