Facility managers regularly encounter hazardous materials. Whether it is hazardous waste that being stored at a facility or a corrosive compound a tenant uses, it is imperative that the utmost care be used with these products in order to prevent injury and reduce risk. A key tool that can be used to avoid trouble is improved communication. Requirements for this communication are found in the OSHA-issued Hazard Communication Standard.
What is the HCS (Hazard Communication Standard)?
The OSHA-issued Hazard Communication Standard (HCS) requires all employers to identify hazardous substances, label them, and train all employees in proper storage, use, and handling techniques. A hazardous substance is any substance that presents a health or physical hazard. OSHA issued the HCS to ensure that workers are informed about the possible harmful effects of chemicals in the workplace. This regulation is often called the HAZCOM Standard or Employee Right-to-Know. The standard is in 29 CFR 1910.1200. The purpose of the Hazardous Communication Standard is:
- To provide a safe and healthy workplace when handling hazardous chemicals
- To train employees to recognize chemical hazards and protect themselves from exposure
- To provide a formal mechanism that identifies the chemical hazards in the workplace and the management/engineering controls necessary to protect workers from exposure
Facility owners, managers, tenants, and contractors who use hazardous chemicals or materials must comply with all the requirements of the HCS. Facility owners are responsible for the actions of all people who work in their buildings, including contractors. These actions include appropriate use and storage of hazardous chemicals as well as the implementation of a formal Hazard Communication Program. Employees must be informed of the hazards of the chemicals they use and trained to themselves from those hazards. Simply stated, owners and managers are required to inform all building employees, tenants, and contractors of all hazardous materials they may come in contact with in the workplace.
HCS training requirements
Provision 29 CFR 1910.1200(h) requires owners to provide hazard communication training for their employees when they are assigned to work with a hazardous chemical. This responsibility may be given to a manager, but the owner/employer is ultimately liable. The intent of this provision is to have information prior to exposure. This purpose cannot be met if training is delayed.
The training provisions of the HCS are not satisfied solely by giving employees the data sheets to read. An employer’s training program is to be a forum for explaining not only the hazards of the chemicals in their work area, but also how to use the information generated in the hazard communication program. This can be accomplished in many ways (audiovisuals, classroom instruction, interactive video), and should include an opportunity for employees to ask questions to ensure that they understand the information presented to them. Training need not be conducted on each specific chemical found in the workplace instead, it may be conducted by hazard category (e.g., carcinogens, sensitizers, acutely toxic agents).
Furthermore, the training must be comprehensible. If the employees receive job instructions in a language other than English, the training and information conveyed under the HCS will also need to be conducted in a foreign language. Although this training program does not have to be elaborate or extensive, the OSHA performance standard specifies that employees must receive information and training on all provisions of the HCS. This includes the types of operations in their work areas where hazardous materials are present, together with the location, availability, content, and requirements of the written hazard communication program, list(s) of hazardous materials, and MSDSs (material safety data sheets).
Based on the information typically required during an OSHA inspection, you should document the time, place, and content of all hazard communication training sessions for program evaluation or audit purposes. Employees should also sign an attendance sheet indicating they attended specific sessions. This will not prevent OSHA from citing you if the employee fails to answer questions properly during an OSHA investigation, but it can aid in tracking the need for refresher training in given areas.
What does baseline, or initial, hazard communication training cover?
Baseline, or initial, hazard communication training should include information about:
- Types of operations in work areas where hazardous materials are present
- Location, availability, content, and requirements of the written hazard communication program
- Location and availability of hazardous materials inventory
- Location and availability of MSDSs
- Methods that employees can use to detect the presence or release of toxic chemicals in the workplace
- The visual appearance or odor of hazardous materials that might be released
- Any alarm or warning systems
- The existence of any environmental or medical monitoring programs
- Physical and health hazards associated with the chemicals in their work areas, including target organ effects
- Specific measures to protect employees from the hazards in their work areas, such as engineering controls, safe work practice guidelines, emergency procedures, and personal protective equipment
- Specific components of the hazard communication program, including explanations of the labeling system used in the facility and the methods employees can use to obtain hazardous chemical information
Baseline, or initial, training should last from two to four hours for most workplaces. Some form of written test must be given to document whether employees understand what was covered. Although OSHA does not specify requirements for trainers, ideally the training should be performed by instructors who have at least two years of experience in adult education programs. In addition, they must be knowledgeable about handling hazardous materials. If an in-house manager is selected to train employees, that person should attend a “train-the-trainer” course on hazard communication.
Training should present employees with the answers to questions such as: Where are your written program and MSDSs located? What is the hazard of the material you are working with? Even with proper documentation, citations for training violations will be issued if employee performance is lacking.
As new hazardous materials are introduced in the workplace, give employees refresher training so they can learn the potential hazards these materials present before they are used. If, for example, the newly introduced solvent is a suspected 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. If, on the other hand, 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. A supervisor or manager can conduct this training.
The employer does not have to retrain each new hire if that employee has received training from a past employer, an employee union, or any other entity. General information, such as the basics of the HCS, can be expected to remain with an employee from one position to another. The employer, however, maintains the responsibility to ensure that their employees are adequately trained and have the knowledge and information necessary to conduct their jobs safely. 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. An employer, therefore, must evaluate an employee’s level of knowledge of the hazards in the workplace, the requirements of the standard, and the employer’s hazard communication program.
Some states, such as New York, require yearly refresher courses for all government employees, but the state plan does not cover private sector companies/employers. Owners and managers must make sure that they comply with both federal and state requirements. Training may be adequate and employees may fully understand the HCS requirements, but if documentation is lacking, violation citations may be issued.
The HCS requires owners and managers to create and use a written hazard communication program. This written plan must be available to regulatory agencies, employee representatives, and employees. The program does not have to be complicated or lengthy. Formats for a written hazard communication program can be obtained through health and safety consultants or off-the-shelf computer programs and manuals. If you use a computer program, make sure it is appropriate for your facility and covers all chemicals on-site.
This article is excerpted from BOMI International’s Contaminants Reference Guide.. TMore information regarding this is available by calling 1-800-235-2664, or by visiting www.bomi.org.
You can get a copy of standard in 29 CFR 1910.1200 from the U.S. Government Printing Office or from your regional OSHA office. You can visit OSHA’s website at www.osha.gov for more information.