Training Methods
It's important to understand that employees must be trained at the time they are assigned to work with a hazardous chemical.
The intent is to inform employees 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.
Training requirements are not satisfied solely by giving employees the SDS 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 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 or online instruction
- interactive video
- hands-on demonstration (This should always be included in training.)
Regardless of the training method, all employees should have an opportunity to ask questions to ensure 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 are a couple of examples to help you 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.
Knowledge Check Choose the best answer for the question.
6-3. Why is HAZCOM training conducted prior to an employee's first exposure to the hazardous chemical?
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