What You Don

What You Don't Know Can Hurt You

Employees must be trained on the hazardous chemicals in their work area. What do employers need to know to comply with standards and protect their employees effectively?

The potential for accidents, incidents, and injuries is always present when people work with, or are in the vicinity of, hazardous chemicals. OSHA estimates that 43 million workers produce or handle hazardous chemicals in more than five million workplaces across the country. That’s a lot of potential! The good news, though, is that Hazard Communication (HazCom) training can help ensure chemical safety in the workplace. 

When employees know and understand the hazards of the chemicals they work with and how to safely use them, they can greatly decrease any risk that might be present. OSHA’s HazCom Standard at 29 CFR 1910.1200 requires you to communicate this information.

All employees exposed to hazardous chemicals in the workplace must be provided with information and training on the hazardous chemicals in their work area. “Exposure or exposed” is defined in the standard to mean “that an employee is subjected in the course of employment to a chemical that is a physical or health hazard, and includes potential (e.g., accidental or possible) exposure. “Subjected” in terms of health hazards includes any route of entry (e.g., inhalation, ingestion, skin contact or absorption).” 

How Does OSHA Define Hazardous Chemical?

Under HazCom, a hazardous chemical is defined as “any chemical which is classified as a physical hazard or a health hazard, a simple asphyxiant, combustible dust, pyrophoric gas, or hazard not otherwise classified (HNOC).” A physical hazard or health hazard may pose any of the hazardous effects listed below:

 

Physical Hazard:

  • Flammable (gases, aerosols, liquids, or solids) 

  • Oxidizer (liquid, solid, or gas) 

  • Self-reactive 

  • Pyrophoric (liquid or solid) 

  • Self-heating 

  • Organic peroxide 

  • Corrosive to metal 

  • Gas under pressure 

  • In contact with water emits flammable gas

Health Hazard:

  • Acute toxicity (any route of exposure) 

  • Skin corrosion or irritation 

  • Serious eye damage or eye irritation 

  • Respiratory or skin sensitization 

  • Germ cell mutagenicity 

  • Carcinogenicity 

  • Reproductive toxicity 

  • Specific target organ toxicity (single or repeated exposure) 

  • Aspiration hazard

Section 2 of a safety data sheet (SDS) tells you whether a chemical is considered hazardous. It identifies the hazards of the chemical and the appropriate warning information associated with those hazards. The required information includes: 

  • The chemical’s hazard classification (e.g., flammable liquid, category); 
  • Signal word; 
  • Hazard statement(s); 
  • Pictograms; 
  • Precautionary statement(s); 
  • Description of any HNOC; and 
  • For a mixture that contains an ingredient(s) with unknown toxicity, a statement describing how much (percentage) of the mixture consists of ingredient(s) with unknown toxicity. This is a total percentage of the mixture and not tied to the individual ingredient(s). 

Getting Started With Training

Your written HazCom program can serve as a training blueprint, as it reflects what your company is doing to comply with the provisions of the standard and to protect employees from chemical hazards. It should include a list of all hazardous chemicals in the workplace and address:

  • Training on chemicals in the work area; 
  • Labels on shipped and in-house containers; 
  • SDSs; 
  • The methods used to inform employees of the hazards of non-routine tasks and the hazards of unlabeled pipes in their work area; and
  • Multi-employer workplaces. 

What Must Be Covered in Training?

Employees must be trained at the time they’re assigned to work with a hazardous chemical and whenever a new chemical hazard is introduced. Annual training is a best practice and refresher training may be provided as needed, i.e., if employees are working unsafely. 

OSHA allows you to design information and training to cover specific chemicals or categories of hazards, such as flammability or carcinogenicity. If you have few chemicals, you may wish to train on specific chemicals, while a large number of chemicals may be better suited to training by hazard category.

Training must include: 

  • An explanation of the HazCom Standard at 1910.1200. In sum, the standard gives employees the right to know and understand the hazards of the chemicals they work with. Information about chemical hazards must be passed downstream from the manufacturer, importer, or distributor to the employer, who then shares it with employees who will be exposed to these hazards. This information is in the form of labels and SDSs; 
  • The location, availability, and details of the employer’s written HazCom program, including the required list of hazardous chemicals;
  • How to read SDSs and use the information they contain (i.e., first aid information), and how to access SDSs in the workplace (i.e., binder or computer in the work area); 
  • An explanation of the labels received on shipped containers and the workplace labeling system used by the employer (if different than on shipped containers); 
  • Operations in the work area where hazardous chemicals are present; 
  • How to detect the presence or release of a hazardous chemical in the work area, such as monitoring conducted by the employer or continuous monitoring devices; 
  • The physical and health hazards of the chemicals in the work area; and 
  • How employees can protect themselves from these hazards, including specific procedures the employer has in place to protect employees, such as appropriate work practices, emergency procedures, and personal protective equipment (PPE) to be used. 

If you have employees who do special, non-routine tasks that may expose them to hazardous chemicals - such as a tank clean out - you must inform them of those chemicals’ hazards, how to control exposure, and what to do in an emergency. This also means evaluating the hazards of these tasks and providing appropriate controls, including protective equipment and any additional training as required.

You also must inform employees of the hazards associated with chemicals contained in unlabeled pipes in their work areas.

And finally, on multi-employer worksites, the employer is responsible for providing updated training when their employees are exposed to new hazards, even if these hazards are created by other employers. 

What Kind of Training Is Acceptable?

Computer-based or video-based training can provide an overview of HazCom and its requirements. OSHA says, however, that this type of training on its own does not meet the intent of the standard. You also must cover site-specific information, that is, the chemicals that are present in your workplace, the details of your written HazCom program, the location of SDSs, and your workplace labeling system if it’s different than that on shipped containers.

Employees must have the opportunity to ask questions and receive answers in a timely manner. If employees receive work instructions in a language other than English, training must be provided in that language. It’s also important to consider the education and technical background of the employees to ensure that they completely understand the information. For example, if employees have low literacy, you may consider verbal instruction versus reading documents. 

No formal certification is required for a person to conduct HazCom training. However, OSHA does expect that the trainer has the knowledge and understanding to present the information so that it’s understandable to all employees and that it’s specific to the workplace. The trainer must be familiar with: 

  • The requirements of the standard that apply to the workplace; 
  • The hazardous chemicals in the workplace to which workers are exposed, as well as the types of hazards they pose; 
  • The written HazCom program implemented in the workplace; and 
  • The measures used in the workplace to protect workers. 

As the employer, you may determine who’s qualified to conduct training. That may be someone within your company or a third party. 

Keeping records that document who was trained, when the training was conducted, and what was covered helps to document compliance with OSHA’s training requirement in case of an inspection. 

Key to Remember

An effective HazCom training program helps ensure employees’ safety when they’re exposed to hazardous chemicals in the workplace.

This article originally appeared in the June 2024 issue of Occupational Health & Safety.

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