Building a Strong Hazard Communication Training Program
An OSHA initiative means employers who use hazardous chemicals in the workplace should start preparing to update their hazard communication training programs. Who needs training, what are the elements of training, and how do you make an effective program?
- By Marc Juaire, Nicole Lyman
- Aug 01, 2023
OSHA is preparing to update its Hazard Communication Standard (HCS) to align with Revision 7 of the United Nations Globally Harmonized System of Classification and Labelling of Chemicals (GHS). This follows Health Canada, which published a final rule to update its Hazardous Products Regulations (HPR) in January 2023.
This alignment is intended to increase worker protection and help reduce chemical-related occupational illnesses and injuries by further improving the accuracy and clarity of information on labels and safety data sheets (SDSs) for hazardous chemicals. These impending changes mean employers who use hazardous chemicals in the workplace should start preparing to update their hazard communication (HazCom) training programs.
Purpose of Hazard Communication Training
OSHA designed the HCS to ensure chemical safety in the workplace by informing employees about the hazards of chemicals they work with and understanding how to minimize risk of exposure. To further reduce risk of injuries and illnesses, the HCS requires employers to provide comprehensive HazCom training to their employees.
Effective HazCom training equips employees with the ability to interpret and understand the hazard information provided on the chemical labels and SDSs for the chemicals they’re working with, and how to apply this information in the workplace.
Proper HazCom training also helps employers comply with OSHA regulations and avoid costly fines and legal penalties. In 2022, HazCom was the second-most-common workplace violation based on OSHA’s Top 10 List of Most Frequently Cited Standards. Violations can result in fines up to $15,625 per violation, per day. In addition, potential criminal charges and possible civil lawsuits may also result from failing to meet HazCom requirements. Ineffective HazCom training is often at the root of these violations and can lead to lost profitability due to fines or lost revenue from employees being unable to work due to chemical exposure.
Who Needs Training
HazCom training is a foundational element of workplace safety, and it’s important to ensure the right people are being trained. According to OSHA HCS, all employees who work with or might be expected to work with hazardous chemicals require training. OSHA states that this scope is intentionally broad, and “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.”
Having close familiarity with the operations, job tasks involved, associated chemicals, and the possible routes of exposure will help to determine which employees require training. At a minimum, evaluate and verify training for all new employees, transferred employees, and temporary workers and contractors.
For contract and temporary workers, OSHA’s recent guidance on protecting temporary workers, including its Temporary Worker Initiative (TWI), clarifies that staffing agencies and employers share responsibility for worker safety. Staffing agencies should train their people on general HazCom requirements, and on the hazards of chemicals they regularly work with from one job site to another. Contracting (i.e., host) employers are responsible for training contract or temporary workers about workplace-specific hazards and HazCom management in their facilities. Employers should always communicate with the staffing agency/contractor provider to eliminate training gaps.
Elements of a HazCom Training Program
In addition to identifying who needs training, compliance with OSHA HCS means having a thorough written training program in place. OSHA provides a Draft Model Training Program employers can use for reference, but it’s always a good idea to review the regulatory requirements, which are available under OSHA’s 29 CFR 1910.1200(h)(3).
According to the HCS, HazCom training needs to cover at least the following:
- Methods and observations that may be used to detect the presence or release of a hazardous chemical in the work area (such as monitoring conducted by the employer, continuous monitoring devices, visual appearance or odor of hazardous chemicals when being released, etc.).
- The 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 from these hazards, including specific procedures the employer has implemented to protect employees from exposure to hazardous chemicals, such as appropriate work practices, emergency procedures, and personal protective equipment (PPE) to be used.
- The details of the hazard communication program developed by the employer, including an explanation of the labels received on shipped containers and the workplace labeling system used by their employer and SDSs, including the order of information and how employees can obtain and use the appropriate hazard information.
Make the Training Program Effective
There are many modes and methods to conduct HazCom training — from slide decks, videos, e-Learning, in-person classroom exercises, or all the above. When choosing a method, keep in mind that training is most effective when employees are engaged. Make the training interactive and participatory, and at the very least, encourage and allow questions. Employees are more likely to remain engaged throughout the training, and as a result, better understand the materials.
OSHA focuses on determining whether employees understand the chemical hazards in their workplace and are aware of safe work practices. As OSHA says, “The Hazard Communication Standard in 1983 gave the workers the ‘right to know,’ but the Globally Harmonized System gives workers the ‘right to understand.’”
How much understanding does OSHA expect workers to have? A HazCom guidance document for small business entities states, “OSHA does not expect that workers will be able to recall and recite all data provided about each hazardous chemical in the workplace. What is most important is that workers understand that they are exposed to hazardous chemicals, know how to read labels and SDSs, and have a general understanding of what information is provided in these documents, and how to access these tools,” and where to always find this information—even during power outages.
In practice, this means that if most employees speak English, but even a small number are non-English speaking and those employees work with hazardous chemicals, they must be provided training in a language and manner they understand. Employers also must account for any limitations in literacy level, vocabulary, or communications within the workforce.
There are two approaches to training employees on workplace hazardous chemicals. Employees can be trained on all the individual chemicals they may encounter, or on chemical hazard classes and categories. Employees need to complete training before they begin working with hazardous chemicals, whenever new hazards are introduced into the workplace, when there are changes to the HazCom management system, such as replacing your old physical SDS binders with software-based access, or there’s evidence the training wasn’t effective.
A high-quality training program requires measurable or observable outcomes. Establish specific objectives with performance conditions, such as test results, to demonstrate that learning objectives are being met.
Bringing it Together
The purpose of HazCom training is to make sure employees, temporary workers and contractors have the information they need to protect themselves from the hazardous chemicals they work with. The overall goal is to change behaviors and replace unsafe behaviors based on incomplete knowledge with safer behaviors based on accurate hazard information. When training is done well, it promotes transparency and two-way communication between employees and employer that is necessary to improve any EHS culture.
Another resource to help with understanding HazCom training requirements is OSHA’s “Small Entity Compliance Guide for Employers That Use Hazardous Chemicals,” specifically Appendix B which contains useful guidance on training. In addition, EHS software solutions that are designed with specific capabilities for HazCom management, delivery of HazCom training content, and management of training documentation can introduce a new and more effective approach to chemical management, workplace safety, and training performance.
This article originally appeared in the August 1, 2023 issue of Occupational Health & Safety.