Intro to Hazard Communication, Part Five: Getting Your Training Right
In the previous installments of our “Intro to HazCom” series, we went over the basics of HazCom (Parts One and Two), tackled some of the challenges of chemical container labeling (Part Three), and discussed how to develop a solid written HazCom plan (Part Four). If you missed any of these, don’t worry! Simply click the links above to get caught up. If you’ve read our previous posts and you’re ready for a detailed discussion of HazCom training requirements (Part Five), then keep reading. You’ll learn about your training obligations under the HazCom Standard, as well as receive an overview of common compliance mistakes and misconceptions, and some best practices.
What Do I Need to Include in My Training Program?
Good question! You’d be surprised how many times employers put together a HazCom training program without even checking whether they’re covering everything the standard requires.
It’s a good idea to go right to the requirements themselves, which available under OSHA’s 29 CFR 1910.1200(h)(3). According to the Standard, your HazCom training needs to cover the following:
- The contents of the HazCom Standard itself, so that employees clearly understand the requirements of chemical manufacturers to provide safety data sheets (SDSs) and shipped container labels to downstream users, and the responsibilities of their employer to provide them with information about the hazards of the chemicals in the workplace.
- Ways of detecting the presence or release of chemicals, whether through use of monitoring equipment or simple observations, such as odors or visible evidence such as sheens or stains. If you use digital monitors, talk about where they are, what they measure, and how to interpret the readings. Make sure that the methods discussed here line up with the specific chemicals and hazards you have at your facility. If you have compressed gases, let your employees know they should be listening for the telltale hissing sound that means that gas is escaping.
- The physical and health hazards of chemicals in your workplace, including those from simple asphyxiants, combustible dusts and pyrophoric gasses, as well any hazards not otherwise classified. The same principle explained above applies here, too: If the hazard is present in your facility, you’d better be covering it in your training.
- The ways that employees can protect themselves from chemical hazards, including through use of personal protective equipment (PPE), safe work practices, engineering controls, and any other specific procedures or controls you’ve implemented. It’s important to be sure, for both the safety of your workplace and the compliance of your training program, that you actually have some form of exposure control identified for all of the specific hazards present in your facility. Be clear and detailed enough to eliminate any potential confusion. For example, if you use different kinds of respirators because of different chemical exposures, it’s important that your employees understand which chemicals they work with should be conducted with respirators, and which specific types of respirators are used with them.
- The details of the employer’s Hazard Communication Program. During our discussion of Written Plans in Part Four of this series, we made the point that OSHA expects your program to be written like a playbook, describing the specific management practices for the chemicals at your facility. That needs to include how you will manage SDSs and shipped labels, your facility’s chemical inventory, methods for accessing SDSs at your facility, the details of your workplace labeling system, how to properly store chemicals, what to do in the event of chemical emergencies, who to seek out for more information, how/where to access the written plan, and any other details you believe are important for effective HazCom management. We also pointed out that it’s not enough to simply write down (or type up) these details – your employees need to understand them. Remember, your training program and written HazCom plan are complementary pieces of your chemical management system, and changes or updates to one will likely necessitate changes to the other.
Who Needs Training?
That’s another great question! It’s also one that is not asked as often as it should be. Many employers provide HazCom training, and do a pretty good job of it in terms of providing the right training content. Where many employers fall short, however, is identifying all of the workers they need to train.
It basically comes down to the question “Which of my employees may be exposed to hazardous chemicals at work?” In a guidance document, OSHA states that this scope is intentionally broad, and “includes any situation where a chemical is present in such a way that employees may be exposed under normal conditions of use or in a foreseeable emergency.”
Some employers may need to train all of their employees. You need to be familiar with your operations, the job tasks involved, the associated chemicals, and the possible routes of exposure before you can determine which members of your workforce require training.
Don’t forget contract and temporary workers! OSHA’s recent guidance on protecting temp workers, including its Temporary Worker Initiative (TWI), makes it clear that the Agency expects the staffing agency and the host employer to share responsibility for worker safety. If you use contract or temp workers at your facility, you as the host employer will be responsible for training them about the hazards and HazCom management practices at your facility. Make sure that, among other things, your training includes how to access SDSs, since that has a way of becoming important very quickly in the event of an emergency.
Your staffing agency should be training their people on general HazCom requirements, and on the hazards of chemicals they regularly work with from one job site to another. Still, you’ll want to keep open lines of communication with the agency to make sure that each of you understand each other’s roles and responsibilities, and that no gaps in training or communication exist.
How Should I Conduct My Training?
The short answer is “any way you want.” You can use slide decks, films, software-based training, classroom exercises, or all of the above. Whatever training methods and materials you choose, you’ll get better results if you make sure the training is engaging for your employees.
We’ve all sat through training sessions where the instructor simply stood at the front of the classroom and lectured, or simply showed a training video and that was it. Not the most effective method of training, and certainly not the most entertaining, right? You should experiment with ways to make training more interactive and participatory, and at the very least, encourage and allow questions. That makes it far more likely that employees will be engaged throughout the training and better understand the material, which brings us to our next point.
Make Sure Training is Effective
This seems like a no-brainer, right? Training ought to be effective. Unfortunately, we sometimes tend focus more on simply conducting the training and then being able to prove that we’ve done training.
As it turns out, though, even the most well organized records won’t convince OSHA that you’ve met your HazCom training requirements. If OSHA were to come to your workplace to evaluate your HazCom compliance, they’d instead focus on finding out if your employees understand the hazards in their workplace, know how to access SDSs, and are aware of safe work practices. As OSHA says on the webpage for the 2012 HazCom final rule, “The Hazard Communication Standard in 1983 gave the workers the ‘right to know,’ but the Globally Harmonized System gives workers the ‘right to understand.’”
How much awareness does OSHA expect workers to actually have at any given time? OSHA clarified this in a HazCom guidance document for small business entities, which states “OSHA does not expect that workers will be able to recall and recite all data provided about each hazardous chemical in the workplace. What is most important is that workers understand that they are exposed to hazardous chemicals, know how to read labels and SDSs, and have a general understanding of what information is provided in these documents, and how to access these tools.”
Let’s talk about what this means in practice, starting with issue of language. Some employers seem to think they need to train in English, perhaps because they’re confusing their training requirements with the language requirements for SDSs and container labels. In reality, you need to train in a language that your employees understand. This doesn’t mean most of your employees, either – it means ALL covered employees. If most of your employees speak English, but even a small number are non-English speaking and those employees work with hazardous chemicals, you must provide training for those employees in the language they understand.
Going beyond language, you also need to train in a manner your employees understand. This means you must account for any limitations in literacy level, vocabulary or communications within your workforce. The more workers you have, the less likely it will be that a “one size fits all” approach to training will work. For example, training programs that heavily rely only on presentation of written material will not work very well for training workers with limited literacy. As a general rule, if you find that you need to provide an employee with regular job instructions in a certain manner to get the points across, you should provide your HazCom training the same way.
Do you need to train on every chemical you have in your chemical inventory? No, the Standard gives you some latitude there. You can either train your employees on all of the individual chemicals they may be exposed to, or you can group your chemicals by hazard classes and categories and train on those. Do what makes the most sense for you. If you don’t have very many hazardous chemicals, it might be best to just train your employees on all of them. If you have a huge chemical inventory, grouping your chemicals into hazard categories probably makes the most sense.
One of the most overlooked ways to improve the effectiveness of your training is to improve the quality of your training objectives. Most of us who’ve managed HazCom have made mistakes here, your humble author included.
Here’s an example. The first time I ever put together a HazCom training program, I wrote a training objective that said something very much like, “Employees will understand the hazards of the chemicals they work with.” Now, let’s be honest – how many of you have written an objective almost exactly like that one? Why wouldn’t you? It sounds good, and understanding the hazards of chemicals is what it’s all about, right?
It is, but we need to have clear objectives with measurable or observable outcomes to know if we’re really hitting the mark. Looking back at my training objective, we can start seeing the problem. It’s too vague, too general. We don’t really specify how we’ll know that employees are understanding what they should.
It’s better to have more specific objectives with performance conditions spelled out. For example, we might say, “Given an SDS, an employee will correctly locate at least three pieces of designated information,” or “Employee will list correctly the three steps to take in reporting a chemical release.” We can see the difference now: these objectives are not ambiguous, and we’ll know if someone has met them. If they haven’t, we’ll need to revisit our training to find out why, and fix the problem.
Do I Need to Document My Training?
Technically, no. There is no requirement to document training anywhere in the HazCom Standard. That being said, there are pretty good reasons why you should do so.
One of those is that OSHA recommends that you do, and even gets pretty specific about what they think you ought to be documenting.
- Date of presentation
- Learning objectives
- Training program outline
- Names of participants, identified by employee identification number or social security number
- Names of instructors
- Any objective data, such as test results, demonstrating that learning objectives were met
If you take a close look at all of the items on the list, you might start to understand why OSHA stresses their importance, especially in light of what we’ve already discussed about training requirements.
You might recall that we need to provide training again after we’ve changed any aspect of HazCom management, including introduction of new physical or health hazards into the workplace, or after finding evidence that training was not effective. Without the right kind of training documentation, that can be difficult to accomplish.
For example, let’s suppose that we last provided HazCom training before we introduced the first flammable chemical we ever stored at the facility. Records containing the training information listed above would allow us to see that we never trained employees who might be exposed to these chemicals on how to work safely with them. It would also make it possible to quickly identify who these employees were so we could give them the required training as quickly as possible.
You can see why training documentation is one of the keys to keeping our HazCom management system running smoothly and our workforce trained and ready. Of course, maintaining records with this level of detail for all of your workers can be challenging, especially if you have a large workforce or manage HazCom across multiple establishments. Consider the benefits of using modern EHS software to help assign and track training, which will also help you to easily verify that training is complete and understand when you need to provide it again.
Avoid the “Annual Training” Mindset
During my career in EHS consulting and corporate EHS management, I frequently encountered the practice of doing “annual HazCom refresher training.” Often, the practice was accompanied by the belief that OSHA requires employers to conduct annual refresher training. In reality, OSHA requires you to train your employees before they begin working with hazardous chemicals, and whenever you introduce new hazards into the workplace or find evidence that training was not effective.
In my experience, holding the “annual training” mindset can actually be harmful to your HazCom program. Training has a way of becoming fossilized — once every year you dust off your training materials and go through the motions of training your workforce again. During that last year, however, you may have introduced new chemical hazard categories or changed key aspects of your management system, like replacing your old physical SDS binders with software-based access. With this “annual training” mindset, it can be easy to neglect updating your training because you didn’t think it was “time” to do so. As a result, you’re now out of compliance with HazCom requirements.
If you hear anyone in your organization talking about “annual HazCom refresher training,” it’s worth making sure they are aware of OSHA’s actual training requirements, and more importantly, that you’re meeting them.
The Big Picture
I get that all of this can seem like a lot to consider, so I recommend taking a step back at this point to look at the big picture again, because that might help us focus on the right things.
Remember that the reason for HazCom in general, training in particular, is to make sure our workers have the information they need to protect themselves from the hazardous chemicals they work with. What we’re really talking about is changing people’s behavior, replacing unsafe behaviors based on incomplete knowledge of chemical hazards with safe behavior based on accurate hazard information. Effective HazCom training lets us accomplish that. When we do training really well, we also create the kind of transparency and two-way communication between employees and management that is necessary to improve our EHS culture.
If you’re looking for more help with HazCom training, there are a variety of options available. OSHA’s Small Entity Compliance Guide for Employers That Use Hazardous Chemicals is a great resource for understanding HazCom in general, and Appendix B of the Guide has useful guidance on training. Also, be sure to look into EHS software solutions that are designed with specific capabilities for HazCom management, including delivery of training content and managing training documentation.
For our part, we’ll provide you with some additional guidance on common HazCom mistakes and challenges in the upcoming sixth and final installment of our “Intro to HazCom” series. Until then, we wish you safe and happy days.
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