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.
Simply providing employees with the Safety Data Sheet (SDS) to read does not fulfill training requirements. 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 instruction
- Interactive video
- Hands-on demonstration
Regardless of the training method, it is essential that all employees have the opportunity to ask questions to ensure they fully understand the information presented. 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 provided in that language.
Here's a subtle, but important point to remember: Additional training is required whenever a new physical or health hazard is introduced into the work area—not necessarily when a new chemical is introduced. This distinction focuses on the hazard rather than the substance itself. Below are a couple of examples to help clarify 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 a new solvent introduced into the workplace is identified as a suspected carcinogen, and this represents the first introduction of a carcinogenic hazard in the workplace, new training specifically addressing carcinogenic hazards must be conducted. This training is essential for all employees who will be working in areas where they might be exposed to this hazard.
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5-4. What must hazard communication training include regardless of the training method used?
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