How employers can help their workers – and themselves
In recent years, OSHA’s standard on hazard communication (1910.1200) has been the agency’s most frequently cited standard in general industry. A significant area where employers often fall short is training.
Under the standard, employers must provide training to workers who will encounter hazardous chemicals under normal operating conditions or in foreseeable emergencies. That training should occur at the time of an initial assignment or when a new chemical hazard is introduced into the workplace – not necessarily a new chemical or new formulation.
For example, if an establishment has worked only with chemicals that are irritants but brings in one that’s flammable, that’s a new hazard.
Although OSHA doesn’t require training for workers who encounter hazardous chemicals in non-routine, isolated instances, employers tend to provide hazcom training to a broad array of employees to cover their bases, according to Shannon Gainey, technical and regulatory director for consulting firm REACH24H USA.
Another requirement is that training must align with the tasks the worker is performing. That includes information about the hazards of the chemicals with which they’re working, methods to detect the presence or re-lease of those hazardous chemicals, where to find and how to read Safety Data Sheets, what the emergency procedures are, where to find and how to use personal protective equipment, and how to get information from items such as labels and pictograms.
The varied aspects of the Hazard Communication standard, understanding/measuring potential chemical exposures and providing the proper relative training are among the reasons why, experts say, employers likely need help – internally or externally – to navigate their way.
“That’s a big failure of a lot of programs,” Product Safety Solutions President Daniel Levine said. “They don’t have access to someone who can make sure their employees are safe.”
Write it down
Another common issue employers have with the Hazard Communication standard? Not following the program.
For example, if a hazcom program document states that training will be conducted in-person but the organization switches to virtual training without updating its document, that’s a violation.
“Your written hazcom program needs to reflect what you’re actually doing,” said Chandra Gioiello, vice president of consulting firm IHSC.
The good news, Gioiello added, is employers can make their written program as general as possible, “to give themselves enough leeway.” However, they must make sure the document includes “what their training is going to consist of – basically an overview.”
Gainey noted that employers can help themselves by not writing down specific names of trainers in the document, in case those trainers leave the organization. “My recommendation is to keep it simple, even for names,” she said. “Otherwise, you’re always reviewing and updating documents.”
Additionally, it’s important to document which employees have received training. This can bolster evidence of compliance with the standard.
Review and audit
Another helpful step is to review your hazcom program on a regular basis (e.g., once or twice a year) to make sure it’s up to date.
Associate Editor Alan Ferguson discusses this article in the June 2021 episode of Safety+Health's “On the Safe Side” podcast, and Chandra Gioiello, a source for this piece, gave a longer interview on hazcom on the July 2022 episode.
Third-party audits every couple of years or so, Gainey says, are a good way to see if gaps exist in an organization’s hazcom training or its overall program. She pointed out that voluntary International Organization for Standardization standards recommend conducting audits and reviewing all safety-related documents.
Likewise, Gioiello said near misses can expose gaps in training, while listening to feedback from employees can prove helpful as well. For instance, they might let you know that a certain chemical is difficult to work with or they don’t understand how to handle it safely.
“Make sure they can give feedback without any repercussions,” Gioiello said.
It’s also a good idea to review your training to ensure it’s delivered in a language that all workers understand.
Hazcom training should include an opportunity for employees to ask questions to make sure they understand the information they’re given, OSHA notes on a webpage of frequently asked questions.