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Model Program |
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COSHA’s Hazard Communication Standard (HCS) is designed to protect
against chemical source illnesses and injuries by ensuring that
employers and employees are provided with sufficient information to recognize chemical hazards and take appropriate protective measures. Employers are required to provide this information through comprehensive chemical hazard communication programs that include material safety data sheets (MSDSs), labels, and worker training. It can be challenging for employers to institute and maintain effective hazard communication training, either because of a lack of understanding of what kind of training is required, or because of a lack of knowledge on how to conduct effective training. The following Model Training Program has been developed to help employers comply with the training requirements of the HCS. The purpose of hazard communication training is to explain and reinforce the information presented to employees through the written mediums of labels and material safety data sheets, and to apply this information in their workplace. Labels and material safety data sheets will only be successful when employees understand the information presented and are aware of the actions to be taken to avoid or minimize exposure, and thus the occurrence of adverse effects. Training helps to integrate and classify the many pieces of information that relate to chemical hazard communication. In a typical workplace, a worker may be confronted with posted hazard warnings, signs, tags, incoming labels, workplace labels, material safety data sheets (MSDSs), manuals explaining the company hazard communication program, lists of chemicals, and information furnished by the union. This wide variety of communications will differ in format, content and reading level. These differences can obscure the important hazard communication message. Training can reduce this background “noise” by presenting the necessary information in a structured and logical manner. Training sessions serve another important purpose — they provide a forum for employees to share their health and safety concerns, and to obtain answers from managers and occupational health and safety professionals. Employees can also share their ideas and job experiences — they often have acquired real expertise in dealing with potentially hazardous situations. Specific Requirements Paragraph (h) of the HCS addresses employee information and training. The requirements reflect the overall purpose of the standard. First, employers should provide employees with effective information and training on hazardous chemicals in their work area at the time of their initial assignment, and whenever a new physical or health hazard that employees have not been previously trained about is introduced into their work area. Information and training may be designed to cover categories of hazards (such as flammability or carcinogenicity) or specific chemicals. Chemical-specific information must always be available through labels and material safety data sheets. Second, employees shall be informed of the requirements of this section; Any operations in their work area where hazardous chemicals are present; The location and availability of the written hazard communication program, including the required list of hazardous chemicals, and material safety data sheets required by this section. Third, employee training shall include at the least: 1. 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.); 2. Physical and health hazards of the chemicals in the work area; 3. Measures employees can take to protect themselves from these hazards, includingspecific procedures the employer has implemented to protect employees from exposure to hazardous chemicals, such as appropriate work practices, emergency procedures, and personal protective equipment to be used; and 4. Details of the hazard communication program developed by the employer, including an explanation of labels and material safety data sheets, and how employees can obtain and use the appropriate hazard information. What does all this information and training requirements mean? Effective means that the information and training program must work. Employees must carry the knowledge from the training into their daily jobs. For example, if asked, they should know where hazardous chemicals are present in their work area, and should also know how to protect themselves. In their work area: means just what it says. The information and training must be specific to each work area. You can’t stop at training about general hazards found in work areas; you have to address the potential hazards that employees are actually going to encounter. Time of initial assignment: This means that new employees must be informed and trained before going on the job, so that they are not faced with unknown hazards. New physical or health hazard: Sometimes new hazardous chemicals are introduced into the workplace, and sometimes employees are assigned to new jobs that involve potential exposure to new hazards. Either way, no employee should be in the position of encountering unfamiliar or unknown hazards. Categories of hazards: OSHA is aware that many workplaces contain so many different chemicals that it would be difficult and confusing to attempt to train employees about each one separately. Fortunately, many chemicals fall into categories, such as flammables or acids and bases. In these instances, it is not only acceptable but also more effective to discuss the hazards of the category as a whole. If individual chemicals within a category present a special safety or health hazard, these unique properties must be pointed out. Specific chemicals are those that don’t belong in a category or should be singled out for some other reason. For example, they may present a special hazard, or be represented in great quantity in the workplace. Chemical-specific information must always be available through labels and material safety data sheets. Whether categories or any other training method is selected, labels and MSDSs must always be available and accessible to employees at all times. Informed: Providing information is not quite the same as training, but OSHA has included both under the general term “training.” It means that employees must know what the standard means and where things are kept. Information can be furnished with the help of signs, notices, handouts, or other means. Whatever information measures are chosen, however, they must be effective. For example, employees should be able to tell you where the written program is housed, and also to locate the material safety data sheet collection. Requirements of this section are simply the requirements of the HCS. It is a good idea here to inform the employees about the rights and responsibilities of the employer as well as the employee. Operations in their work area: This phrase points again to the need to be specific in the information and training program. Generalities about operations that have no relevance to these specific employees are not sufficient. Location and availability must again be specific. For example, the written hazard communication program may be kept in Building A or in the supervisor’s office, where it must be available at all times. Employees should know exactly where it is and how to gain access. Training: This term covers anything that is done to impart new knowledge or skills or to refresh employees’ memories on previously learned knowledge or skills. It can best be imagined as bridging the gap between what employees know now and what they have to know to identify hazards and protect themselves against them. Many different training methods and media can be used to achieve this goal. Methods and observations mean any active or passive means that can be used to detect the presence or release of a hazardous chemical. For example, some chemicals such as chlorine can be detected by their odor, color or other unique properties. Physical and health hazards apply only to the physical and health hazards of chemicals. A physical hazard is associated with a chemical that is a combustible liquid, a compressed gas, explosive, flammable, an organic peroxide, an oxidizer, pyrophoric, unstable or water-reactive. All these can harm as a result of physical reaction. Health hazard means that exposure to the chemical can cause acute or chronic health effects. Examples are carcinogens and eye irritants. Measures employees can take to protect themselves include any control, including everything from learning the meaning of emergency signals to observing “No Entry” areas or selecting the correct personal protective equipment. Details of the hazard communication program allow employees to learn what label statements mean, what information can be found in the material safety data sheet, and how to find out if a chemical presents a potential hazard. What are some common problems encountered with training? In the brief definition above, OSHA says that to be effective, training must “work.” Training sometimes does not work, for the following reasons: • Training is not the solution. This means that poor performance by employees is not due to a lack of knowledge and skills. Other actions, such as the implementation of engineering controls, might be the better answer. • Training is too generic. Instead of focusing on specific hazards in the workplace, some employers make the mistake of only showing videos that deal with industry situations in general. • Special needs and preferences of adult learners are not taken into account. • Inappropriate training methods and media are selected. Some employers have spent a great deal of money on training media that are not necessarily effective. Often, simple and inexpensive methods are more effective in achieving the goals of a hazard communication program. • There is no transfer of learning from the training setting to the job. This commonly occurs when the training is a “one-shot” deal, with no further follow up in the work setting. • No evaluation of training effectiveness is made. To make sure that training is achieving its goals, it is valuable to measure its effectiveness. This will tell you whether employees achieved the level of knowledge and skill that was expected. If they didn’t, appropriate revisions can be made and the training can thus be improved. • Documentation of training is not adequate. Although there is no requirement to document training, it makes sense to maintain records. Recording class attendance is not enough; you also need to document what it was you set out to teach and how well you achieved it. FSM |
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