Although OSHA’s requirements for HazCom training remain flexible now that GHS is here, there are some changes you need to know about and some basic requirements you need to incorporate.
Despite the fact that OSHA allows you to make many training decisions concerning hazard communication under the amended standard, employee training must nevertheless include certain basics. For example, you must teach employees:
- Methods and observations used to detect the presence or release of a hazardous chemical in the work area, such as monitoring conducted by the employer, continuous monitoring devices, visual appearance or odor of hazardous chemicals when being released
- Physical, health, simple asphyxiation, combustible dust, pyrophoric gas, and hazards not otherwise classified of the chemicals in the work area
- Protective measures to prevent injuries and illness
- How to detect the presence of a hazardous chemical
- Specific protective procedures you are providing, such as engineering controls, work practices, and PPE
- An explanation of the labels received on shipped containers and the workplace labeling system used, and an explanation of the new safety data sheet (SDS), including the chronological order of information on the SDS and how employees can use the appropriate hazard information
Be sure to revise employee training for the SDSs and chemical labels by December 1, 2013. By that date, you must have updated your training so that employees will learn to identify the classes of physical and health hazards and read and interpret the new chemical labels and SDSs.
The amended standard also requires you to provide additional employee training by June 1, 2016 for new physical or health hazards identified by you or described in SDSs or chemical labels since the last training.
Get ready for compliance with the new OSHA amendments to HazCom. BLR’s GHS Compliance Focus will help you understand how GHS changes hazard communication requirements and what you need to do to comply. Try it.
OSHA Training Guidelines
Here are some recommended hazard communication training guidelines that will help ensure compliance:
- According to OSHA HazCom guidance materials, training can be accomplished through a combination of audiovisuals, classroom instruction, and interactive video.
- Training can be conducted or information provided by categories of hazard (such as carcinogens or toxic agents) rather than by specific chemical.
- Training is required for new physical or health hazards, not for every new chemical that enters the workplace. If, however, a newly introduced chemical does not fit into an existing hazard class or category, training for that new chemical must be provided.
- A general discussion of hazardous chemicals or giving employees an SDS to read, for example, is not enough. If an OSHA inspector concludes that the training is inadequate, a more rigorous review of the company’s entire compliance program will probably follow.
- You are responsible for evaluating an employee’s level of knowledge concerning hazards in the workplace and the hazard communication program.
SPECIAL NOTE: According to OSHA guidelines, if employees receive job instructions in a language other than English, the training and information conveyed under HazCom should also be presented in that language.
BLR’s GHS Compliance Focus provides the compliance dates along with a side-by-side comparison of the HazCom standard before and after the GHS amendments. Get the details.
Get Ready for GHS!
BLR’s GHS Compliance Focus is a must-have for any workplace that is required to have a hazard communication program. Recent changes to OSHA’s HazCom standard require changes to your safety program and training content. And you have to get started soon!
This report describes in detail OSHA’s hazard communication ("right-to-know") requirements for both general industry and construction worksites, including OSHA’s adoption of the Globally Harmonized System of Classification and Labeling of Chemicals (GHS). OSHA’s HazCom rule for the construction industry adopts the general industry rule by reference.
Remember it is not too soon to start thinking about compliance. The HazCom amendments became effective May 25, 2012. Although the GHS compliance requirements will be phased-in over a 4-year period, you need to start now to keep on target.
GHS Compliance Focus is just what you need to make sense of the new rules. The report provides you with compliance dates along with a side-by-side comparison of the HazCom standard before and after the GHS amendments.
To help you understand and comply with the new HazCom requirements, we’ll be happy to make GHS Compliance Focus available for a no-cost, no-obligation, 30-day evaluation in your office. Just let us know, and we’ll be pleased to arrange it.