HazCom 2012 Training From a Legal Perspective

MSDSonline had the opportunity to conduct a Webinar on GHS this week with Adele L. Abrams, a lawyer specializing in safety law. It was a great chance to look at HCS compliance through another perspective. There were several key takeaways from Ms. Abrams portion of the program we thought worth sharing with our readers.One of the comments Abrams made early on was about the importance of HazCom 2012 training. Of course the first HCS deadline, December 1, 2013, is centered on training employees on how to read and understand GHS formatted labels and safety data sheets. However, something Abrams pointed out was how important it is going to be to document the training that takes place. She explained that in the coming years, OSHA is going to be paying extra special attention to this area, and companies would be wise to be prepared to provide evidence of their training compliance.

Abrams also reminded participants that training must be done in the language employees understand. She said, “If work instructions are given in a language other than English, OSHA may expect training to be in that same language to be effective.” As an exclamation point to this, Abrams called attention to OSHA’s recent focus on workplace protection for immigrants and Latino workers.

The MSDSonline EH&S blog can attest that training is the area of greatest concern for many of its readers, and MSDSonline has been quick to respond with a brand new HazCom 2012 online training course. Additional courses are under development.

Another item Abrams presentation touched on was MSHA’s take on GHS. She pointed out that the Mine Safety Health Administration had not yet placed the HazCom revision on its agenda. Nevertheless, in conversations she’s had with people close to the issue, it looks like MSHA may be prepared to accept compliance with HazCom 2012 even before changes are formally made to MSHA Standard 30 CFR Part 47. The key phrase in the last sentence being “may be prepared”…meaning there’s nothing official…but it’s something to have on the radar.

If you would like to learn more about Adele Abrams and her safety law practice, visit www.safety-law.com

To learn more about MSDSonline and our GHS related solutions, visit www.MSDSonline.com

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