What would happen if an OSHA inspector walked in your door at this very moment and asked your employees questions about the chemicals they use at work? How would they answer? Would they be familiar with the hazard communication standard? And material safety data sheets?

If you answered no to any of these questions, you’re not alone. Time and again inspectors find that employees don’t have even a rudimentary knowledge of the hazards presented by the chemicals they use in the workplace. That’s why the hazard communication standard (Sec. 1910.1200) always tops the list each year for the most frequently cited regulation.

Just why is HazCom training such a challenge for employers? Companies complain that there are just too many chemicals in the workplace to explain. Also, workers aren’t chemists; yet, the material safety data sheets, which contain essential safety information about the chemicals, are written in technical, scientific jargon that is difficult to comprehend. Finally, it isn’t easy to keep up-to-date with changes in chemicals, mixtures and new safety and health information. 

As a result of these obstacles, many employers just give up. They shouldn’t. While the standard does require a certain amount of time and effort, no one, including OSHA, expects you to turn your employees into chemistry PhD’s.

Common-sense objectives
Here is what OSHA says about training employees on hazardous chemicals: 

"Giving an employee a data sheet to read does not satisfy the intent of the standard with regard to training." (Sec. 1910.1200, App. A) 

On the other hand, the agency says this: 

"OSHA does not expect that every worker will be able to recite all of the information about each chemical in the workplace." (Sec. 1910.1200, App. E). 

How to strike a balance between these extremes is the goal of an effective training program.

The American Industrial Hygiene Association recognized the difficulties in developing an appropriate training program for such an encompassing standard.

The Association recommends that employers do the following:
• Provide all hazard information in the primary language of the intended audience and in a format that is targeted to the audience's educational and literacy level.
• Use training methods that are creative, interactive, and job-specific

Start at the beginning
Just how to accomplish these goals is sometimes easier said than done. Consultant Ronnie Good of Columbus, Miss, who assists employers in developing written safety programs advises taking an inventory of workplace chemicals. Then he trains on how to read the MSDSs, where they're located, who's responsible for cleaning up spills, how to understand labels, what target organs are affected, appropriate personal protective equipment (PPE) to use, etc. 

"As I'm training, I think about what an OSHA inspector would ask," he says.

For ongoing training, Good suggests reviewing three or four MSDSs per month. Then, conduct a spot check quiz to see if the employees understand how to handle the hazardous substances and what the risks are.

Another helpful training tip that some employers use is a MSDS Information Review Form that contains critical information and is more user-friendly than the full MSDS, which is always available when more details are needed. Another technique is to use a highlighter to emphasize the important information on the MSDS. Also you can provide a handout of a glossary of chemical terminology.

So many chemicals, so little time
You may have hundreds of chemicals at your worksite. Try grouping chemicals by categories and train according to these groupings. 

One example of different classes of chemicals is: solvents, acids, bases, toxic dusts, gases. Another type of classification can be flammables, corrosives, caustics, carcinogens, etc. A third way of grouping chemicals is by the hazards they present: inhalation hazards, contact hazards, etc. Once you teach about the groups, then you can deal with additional information about individual substances in each group.

Good also suggests looking at the quantities used. 

"You will want to go into much more detail if you're dealing with 30,000 gallons of a chemical compared with a 5 gallon container," he says.

The chemical manufacturer has the responsibility of determining whether a chemical is hazardous and requires an MSDS. Therefore, most employers take the position that any chemical with an MSDS is hazardous and train their workers accordingly.

Frequency of training
Just how often do you need to train your employees? The federal OSHA standards only say that employees need to be trained when they first start the job and then whenever the hazard changes. In other words, annual training is not required, although most employers prefer to do it to keep the information fresh in everyone's mind. Many state Right-to-Know laws do require annual training, so you need to check your local laws.

This requirement does not mean, however, that you need to train employees each time a new substance arrives at the workplace. 

"Training would have to be provided to employees when new hazards are introduced into the workplace (not necessarily new chemicals). If the initial training covers categories of chemicals and hazards and how to read and understand MSDSs, retraining would merely have to ensure that new products and chemicals are identified to the employees and that the hazards, if any, are recognized," said OSHA in a letter response to an inquiry. 

Briefly discussing new chemicals at your weekly or monthly safety meetings would satisfy this requirement.

Emergency procedures
If you are planning to evacuate the area in the event of a spill, fire or explosion, then your training for HazCom will be the same as for any other emergency: alarm systems, evacuation routes and outside meeting areas. 

However, if you expect your employees to take action to control an emergency, such as a spill, then more detailed training is needed on the following procedures: leak and spill cleanup, PPE, decontamination, shutdown, recognizing and reporting incidents.

HazCom training checklist
At the end of your training sessions, your employees should know the following:
• The purpose of the hazard communication standard.
• How to read the hazard information on the MSDSs and labels.
• Where the MSDSs are located.
• What methods are used to detect hazardous chemicals.
• The physical health hazards of the chemicals in the workplace.
• The proper work practices and storage procedures for hazardous chemicals.
• What types of personal protective equipment must be used.
• Procedures to follow in an emergency.

An inspector’s point of view
When you have finished your training program, take the “OSHA Inspector’s Test.” Question your employees about the location of the MSDSs, protective equipment, safe handling of the chemicals and emergency procedures. 

As one OSHA official put it during a recent safety conference, "You might have a great written program, but if we talk to the employees and they do not have a clue, then all you have is a paper product that is worthless.

Read more about safety training at www.trainingonline.com. 

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