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November 27, 2014
HazCom: What Your Workers Don't Know CAN Hurt Them

Employees have the right and the need to know. Workers today are protected against chemical hazards in part by the requirements of OSHA's Hazard Communication Standard (29 CFR 1910.1200). HazCom requires your organization to have a written hazard communication program that covers everything from hazard identification to preventive measures to employee training. Also known as the Right-to-Know law, HazCom is a long and detailed standard, but it's based on a short and simple concept—your employees have both a right and a need to know about the hazards of the chemicals they're exposed to on the job.

Make sure HazCom training covers all the basics. OSHA stresses that the training provisions of 29 CFR 1910.1200 are not satisfied solely by giving employees an SDS to read or telling them to look on the label for hazard information and required precautions. Specific training requirements in 29 CFR 1910.1200(h) include:

  • Information about the standard
  • Operations in the work area where hazardous chemicals are present
  • Location and availability of your written hazard communication program, including lists of hazardous chemicals and SDSs
  • Methods used to detect the presence or release of a hazardous chemical in the work area (sampling and monitoring, for example)
  • Physical and health hazards of the chemicals in the work area
  • Measures workers can take to protect themselves from these hazards, including specific procedures such as appropriate work practices, emergency procedures, and PPE
  • Details of your hazard communication program, including an explanation of your labeling system, how to read and interpret an SDS, and how to use this information to prevent exposure

That's a lot to cover, but ... Remember that you don't have to conduct a training session on each specific chemical found in your facility. Training sessions can cover calssifications of hazards—for example, carcinogens, sensitizers, or acutely toxic agents.

And while you will have to provide additional training whenever a new physical or health hazard is introduced into the work area, you don't have to retrain every time you introduce a new chemical, as long as it doesn't pose new hazards. Of course, you still have to make sure that new employees know the specifics of your organization's hazard communication program, such as where the SDSs are located, elements of the chemical container label, details of your in-plant labeling system, and the hazards of new chemicals to which they will be exposed.

Don't forget about temps and non-English-speaking employees. Temporary workers must also receive hazard communication training. Temporary agencies are only responsible for providing generic hazard training and information concerning categories of chemicals temps may potentially encounter. You are responsible for providing site-specific hazard training. And if yours is a multilingual workplace, OSHA reminds you that hazard communication training must be "comprehensible" to all affected employees. So if you have employees who are not proficient in English and who receive job instructions in a language other than English, then hazard communication training and information to be conveyed under the HazCom will also need to be conducted in a foreign language.

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