Avoiding HazCom training violations

OSHA’s Hazard Communication Standard at 1910.1200 is the most frequently cited General Industry standard, and has been for many years. One of the most-cited provisions within that standard is paragraph (h)(1) on training. In fact, that paragraph was cited more than 800 times during Fiscal Year 2020. This short paragraph contains three requirements:

1. Train employees on hazardous chemicals upon initial assignment,
2. Train employees whenever new chemical hazards are introduced,
3. Ensure that chemical information is available through labels and safety data sheets.

The following outlines common situations that may result in violations.

Initial training

Some employers fail to provide initial training. The fact that another common violation is failing to create a written hazard communication program suggests that some employers are simply not aware of their obligations.

Citations could also mean that some employees were not trained after being transferred to a new area or given new responsibilities. If an employer failed to identify all employees who need training, some workers could be overlooked.

Another possibility is that employees received training, but could not answer an OSHA inspector’s questions about their training. If employees don’t remember key information, then the training wasn’t effective, and OSHA would cite this as a lack of training.

New hazards

Employers can deliver training that covers categories of hazards (such as flammability) or could provide training on the specific chemicals used. If employees work with relatively few chemicals, training might focus only on those chemicals. However, that could require additional training when a new chemical is introduced.

If you introduce a new chemical, verify that training covered the particular hazards of that substance. Consider that even if previous training did cover the hazard, employees might not remember all the details.

Labels and safety data sheets

If labels on containers are incomplete or missing, or if SDSs are not readily available, OSHA will cite the employer. Employees must also understand the labels and know how the obtain SDSs.

To avoid violations and ensure that all workers can protect themselves, consider questioning employees about their training. If they cannot satisfactorily answer questions about the hazards of the chemicals they use, about label elements, or if they don’t know where to find safety data sheets, consider providing refresher training on relevant topics.

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