Hazard Communication Program

Oregon OSHA Online Course 205

This material is for training purposes only. Its purpose is to inform Oregon employers of best practices in occupational safety and health and general Oregon OSHA compliance requirements. This material is not a substitute for any provision of the Oregon Safety Employment Act or any standards issued by Oregon OSHA. For more information on this online course and other OR-OSHA online training, visit the Online Course Catalog.

MODULE FIVE: HAZCOM INFORMATION AND TRAINING

INTRODUCTION

Education is the beginning point for developing and maintaining a world-class HAZCOM program. This module focuses on communicating information about training employees how to work safely while being exposed to chemical hazards. This module also discusses basic employer responsibilities for effectively communicating the HAZCOM to employees.

The "Prime Directive" Employers must provide employees with information and training on hazardous chemicals in their work area at the time of their initial assignment, and whenever a new physical or health hazard employees have not previously been trained on is introduced into their work area. Information and training may be designed to cover categories of hazards (e.g., flammability, carcinogenicity) or specific chemicals. Chemical-specific information must always be available through labels and material safety data sheets.

Information

Employees must be informed of:

• The requirements of the hazard communication standard (OAR 437, Division 2/Z, 1910.1200)
• Any operations in their work area where hazardous chemicals are present, and
• The location and availability of the written hazard communication program, including the required list(s) of hazardous chemicals, and material safety data sheets required by this section.

Training

Employee training must include at least:

• Methods and observations that may be 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, etc.);

  
  

• The physical and health hazards of the chemicals in the work area;

  
  Training need not be conducted on each specific chemical found in the workplace, but may be conducted by categories of hazard (e.g., carcinogens, sensitizers, acutely toxic agents) that are or may be encountered by an employee during the course of his duties.

  
  

• The measures employees can take to protect themselves from these hazards, including specific procedures the employer has implemented to protect employees from exposure to hazardous chemicals, such as appropriate work practices, emergency procedures, and personal protective equipment to be used;

  
  

• The details of the hazard communication program developed by the employer, including an explanation of the labeling system and the material safety data sheet, and how employees can obtain and use the appropriate hazard information.

According to the above, an employer, has a responsibility to evaluate an employee's level of knowledge with regard to the hazards in the workplace, their familiarity with the requirements of the standard, and the employer's hazard communication program.

When do you train HAZCOM?

It's important to understand that employees must be trained at the time they are assigned to work with a hazardous chemical. The intent of this provision is to have information prior to exposure to prevent the occurrence of adverse health effects. Of course, this intent cannot be met if training is delayed until a later date.

Also, training requirements are not satisfied solely by giving employees the MSDS to read. An employer's training program is to be a forum for explaining the who, what, where, why and when (the education) to employees of the the hazards of the chemicals in their work area, but also how (the training) to work safely using safe procedures as required by the hazard communication program. This can be accomplished in many ways, including:

• Classroom instruction
• Interactive video
• Hands-on demonstration

Of the methods listed, hands-on demonstration training is preferred because the evaluation of knowledge and skills is inherent in the training process. Regardless of the training method, all employees should have an opportunity to ask questions to ensure that they understand the information presented to them. Furthermore, the training must be comprehensible. If employees receive job instructions in a language other than English, then the HAZCOM training and information will also need to be conducted in that foreign language.

And, here's a subtle, but important point to remember: Additional training is to be done whenever a new physical or health hazard is introduced into the work area, not a new chemical. Here's a couple of examples that help to understand this requirement:

Example 1. If a new solvent is brought into the workplace, and it has hazards similar to existing chemicals for which training has already been conducted, then no new training is required. However, as with initial training, and in keeping with the intent of the standard, the employer must:

• make employees specifically aware which hazard category (i.e., corrosive, irritant, etc.) the solvent falls within.
• make the substance-specific data sheet available, and
• properly label the new product.

Example 2. If the newly introduced solvent is a suspect carcinogen, and there has never been a carcinogenic hazard in the workplace before, then new training for carcinogenic hazards must be conducted for employees in those work areas where employees will be exposed.

What about retraining new hires? It is not necessary that the employer retrain each new hire if that employee has received prior training by a past employer, an employee union, or any other entity. General information, such as the rudiments of the HCS could be expected to remain with an employee from one position to another. The employer, however, maintains the responsibility and is held accountable to ensure that their employees are adequately trained and are equipped with the knowledge and information necessary to conduct their jobs safely.

Remember, it is likely that additional training will be needed since employees must know the specifics of their new employers' programs such as where the MSDSs are located, details of the employer's in-plant labeling system, and the hazards of new chemicals to which they will be exposed.

Training at multi-employer worksites The training requirements also apply if the employer becomes aware via the multi-employer worksite provision of exposures of his/her employees to hazards for which they have not been previously trained.

Training temporary employees

Training temporary employees is a responsibility that is shared between the temporary agency and the host employer.

• The host-employer holds the primary responsibility for training since the host employer uses or produces chemicals, creates and controls the hazards, and is, therefore, best suited to inform employees of the chemical hazards specific to the workplace environment.

  
  

• The temporary agency, in turn, maintains a continuing relationship with its employees, and would be, at a minimum, expected to inform employees of the requirements of the standard.

Contracts between the temporary agency and the host-employer should be examined to determine if they clearly set out the training responsibilities of both parties, in order to ensure that the employers have complied with all requirements of the regulation.

How extensive should training be?

A frequently overlooked portion of the training provisions is that dealing with emergency procedures. Training is expected to be proportional to the hazards of the workplace. If a chemical is very hazardous, more information would be expected to be provided on the MSDS. Therefore, the training for emergency procedures, including information about the characteristics of the chemical and precautions to be taken, would need to be more extensive.

In situations where employees are expected to moderate or control the impact of the emergency in a manner similar to an emergency responder, training under 1910.120 would be required. Employers who fall under the scope of HAZWOPER must have either a written emergency response plan or an emergency action plan. If employers expect their own employees to respond to a potential emergency involving a hazardous substance, then the employer must create an emergency response plan and the employees must be trained to perform the duties expected.

HAZWOPER does not cover response to incidental spills that do not have the potential for becoming an emergency. Training for responding to such incidental spills would be under the hazard communication standard and would include, at a minimum, leak and spill cleanup procedures and the use of appropriate PPE.

Last words

There you have it? Almost everything you need to know. If you have specific questions about the HAZCOM program, ask an Oregon OSHA technical services representative at our central office (800.922.2689) to help you interpret the rule. Time to take the module review quiz, so let's go. Answer each question as best you can. Scroll up the page to review if you like.

MODULE Quiz

41. When must employers provide employees with effective information and training on hazardous chemicals in their work area?

a. at the time of initial assignment
b. within two days after assignment
c. within one week after reassignment
d. no later than one day after assignment

42. According to the text, employers must provide employees with effective information and training on hazardous chemicals in their work area only when a new chemical is introduced into their work area.

a. True
b. False

43. According to the text, which of the four HAZCOM training methods listed below is most likely to be effective?

a. Interactive video
b. Classroom training
c. Reading a MSDS
d. Hands-on demonstration

44. According to the text, if a new solvent is brought into the workplace, and it has hazards similar to existing chemicals for which training has already been conducted, then _________:

a. training must be conducted within one week
b. all exposed employees must be trained
c. no new training is required
d. additional training is required

45. Hazard communication information and training may not be designed to cover categories of hazards:

a. True
b. False

46. According to the text, employees exposed to hazardous chemicals must be informed of all of the following, except:

a. requirements of the standard
b. chemical storage procedures
c. operations containing hazardous chemicals
d. location of the written program

47. Training temporary employees is primarily the responsibility of the _________:

a. the safety committee
b. temporary agency
c. host employer
d. employment office

48. Training for responding to incidental spills would be initiated under the emergency response plan and would include, at a minimum, leak and spill cleanup procedures and the use of appropriate PPE.

a. True
b. False

Hey, great job! You've completed all the modules. I hope the information within these five modules as been helpful to you and I hope to see you participate in another course soon. When you're ready, go to the Course Assignments and Quiz web page to submit your coursework, evaluation, and certificate information. I'll see you in a workshop or another internet course! If you have any questions or comments, just drop me an email.