What is considered proper training
under the HAZCOM standard?
Employees are to be trained at the time they are assigned to work with a
hazardous chemical. The intent of this provision (1910.1200(h)) is to
have information prior to exposure to prevent the occurrence of adverse
health effects. This purpose cannot be met if training is delayed until a
later date.
The training provisions of the HCS are not satisfied solely by giving
employee the data sheets to read. An employer's training program is to be a
forum for explaining to employees 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, 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.
Furthermore, the training must be comprehensible. If the employees receive
job instructions in a language other than English, then the training and
information to be conveyed under the HCS will also need to be conducted in a
foreign language.
Reference Interpretation and Compliance Letters:
What are the requirements for
refresher training or retraining a new hire?
Additional training is to be done whenever a new physical or health
hazard is introduced into the work area, not a new chemical. For example, 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. 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. The substance-specific data sheet must still be available, and the
product must be properly labeled. 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.
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 to ensure that their
employees are adequately trained and are equipped with 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. For example,
(h)(3)(iii) requires that employees be trained on the measures they can take to protect
themselves from hazards, including specific procedures the employer has
implemented such as work practices, emergency procedures, and personal
protective equipment to be used. An employer, therefore, 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.
Reference Interpretation and Compliance Letters:
Do you need to keep MSDSs for commercial products
such as “windex” and “white-out”?
OSHA does not require that MSDSs be provided to purchasers of household consumer products
when the products are used in the workplace in the same manner that a consumer would use
them, i.e.; where the duration and frequency of use (and therefore exposure) is not greater
than what the typical consumer would experience. This exemption in OSHA's regulation is based,
however, not upon the chemical manufacturer's intended use of his product, but upon how it
actually is used in the workplace. Employees who are required to work with hazardous chemicals
in a manner that results in a duration and frequency of exposure greater than what a normal
consumer would experience have a right to know about the properties of those hazardous
chemicals.
Reference Interpretation and Compliance Letters:
What are the requirements and limits to using
generic MSDSs?
... [Regarding] the suitability of a generic material safety data sheet (MSDS). As you are
probably aware, the requirements for MSDSs are found in paragraph (g) of 29 CFR 1910.1200.
MSDSs must be developed for hazardous chemicals used in the workplace, and must list the
hazardous chemicals that are found in a product in quantities of 1% or greater, or 0.1% or
greater if the chemical is a carcinogen. The MSDS does not have to list the amount that the
hazardous chemical occurs in the product.
Therefore, a single MSDS can be developed for the various combinations of ... [chemicals],
as long as the hazards of the various... mixtures are the same. This "generic" MSDS must
meet all of the minimum requirements found in 29 CFR 1910.1200(g), including the name,
address and telephone number of the responsible party preparing or distributing the MSDS who
can provide additional information.
Reference Interpretation and Compliance Letters:
What is the application of HAZCOM to an office
environment?
Office workers who encounter hazardous chemicals only in isolated instances are not
covered by the rule. The Occupational Safety and Health Administration (OSHA) considers
most office products (such as pens, pencils, adhesive tape) to be exempt under the
provisions of the rule, either as articles or as consumer products. For example, Mrs.
Schissler specifically mentioned copy toner. OSHA has previously stated that intermittent or
occasional use of a copying machine does not result in coverage under the rule. However,
if an employee handles the chemicals to service the machine, or operates it for long periods
of time, then the program would have to be applied.
Reference Interpretation and Compliance Letters:
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