Hazard communication (HazCom) remains one of OSHA's Top 10 violations from year to year. While the regulation at 1910.1200 has numerous requirements, one that often trips up employers is training.
Who needs to be trained on hazardous chemicals and when?
All employees must be provided with information and training on hazardous chemicals in their work area at the time of their initial assignment (prior to being exposed to a chemical), and whenever a new chemical hazard the employees have not previously been trained about is introduced into their work area.
The regulations allow you to design information and training to cover categories of hazards, such as flammability or carcinogenicity, or specific chemicals. Chemical-specific information must always be available through labels and safety data sheets (SDSs).
What does "exposure" mean?
The regulations at 1910.1200(c) define "exposure or exposed" 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.)"
What information needs to be covered in HazCom training?
Employees must be made aware of any operations in their work area where hazardous chemicals are present, and the location and availability of the employer's written hazard communication program, including the required list(s) of hazardous chemicals, and SDSs.
Training must include at least:
- 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 (HNOC), of the chemicals in the work area;
- How employees can protect themselves from these hazards, including specific procedures the employer has in place to protect employees from exposure to hazardous chemicals, such as appropriate work practices, emergency procedures, and personal protective equipment (PPE) to be used; and
- 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; the safety data sheet, including the order of information and how employees can obtain and use the appropriate hazard information.