Hazard Communication Training

The hazard communication (hazcom) standard is one of the most complex of OSHA’s regulations, which is probably why it is cited most often during OSHA inspections.

A key element of this standard is training. Here are some of the most frequently asked questions about hazcom training:

Where do we begin training on such a complex subject?

Start by taking an inventory of the workplace chemicals. Train on how to read the material safety data sheets (MSDSs), where they are located, how to understand labels, who is responsible for cleaning up spills, and what procedures must be followed, what target organs are affected, which PPE should be used, and so on. As you are training, think about what an OSHA inspector would ask.

For ongoing training, review three or four MSDSs per month, then conduct a spot quiz to see if employees understand how to handle the hazardous substances and what the risks are.

Another helpful training tip is to use an MSDS Information Review Form, which contains critical information that is transferred from the MSDS . The review form is more "user-friendly" than the full MSDS (which is always available when more details are needed). Another technique is to use a highlighter to emphasize the important information on an MSDS.  It is also good to provide a handout glossary of chemical terminology.

We have hundreds of hazardous chemicals at our worksite.  How do we train on all of them?

Many employers will group chemicals by categories that make sense for their operation and train according to these groupings. Examples of different classes of chemicals are solvents, acids, bases, toxic dusts, and so on. Other types of classifications can be flammables, corrosives, caustics, carcinogens, etc. A third way of grouping chemicals is by the hazards they present, such as inhalation hazards or contact hazards. Once you teach about the groups, then you can deal with additional information about individual substances in each group.

Is annual training required by the standard?

The federal OSHA standards only say that employees need to be trained when they first start a job and then whenever the hazard changes. In other words, annual training is not required, although most employers prefer to do so in order to keep the information fresh in employees’ minds. Many state "right-to-know" laws, such as in Texas, do require annual training, so you need to check your local laws.

Must we stop and retrain on each new substance that arrives at the workplace?

As long as initial training is comprehensive and covers categories of chemicals and hazards and how to read and understand MSDSs and labels, retraining would merely have to assure that new products and chemicals and any recognized hazard are identified to the employees, as well as how they can protect themselves. Briefly discussing new chemicals and their MSDSs at your weekly or monthly safety meetings could satisfy this requirement.

How do compliance officers check to see if our training is adequate?

A common way of verifying your training program is questioning your employees about the location of the MSDSs, the type of protective equipment they must use, the emergency procedures in place, and when training last occurred. As one OSHA official put it, "You might have a great written program, but if we talk to the employees, and they do not have a clue, then all you have is a paper product, and it is not worth a thing to you."

Other methods of verification include checking the training roster, reviewing the training materials, and looking at the test scores. Therefore, it is extremely important that you document all training sessions and retain employee sign-in sheets and tests. Inspectors will also observe the employees’ work practices or ask them to demonstrate work procedures.

Hazcom Training Checklist

At the end of your training sessions, your employees should know the following:

• The purpose of the hazard communication standard.
• How to read the hazard information on MSDSs and labels.
• Where the MSDSs are located.
• What methods are used to detect hazardous chemicals.
• The physical health hazards of the chemicals in the workplace.
• The proper work practices and storage procedures for hazardous chemicals.
• What types of personal protective equipment must be used.
• Procedures to follow in an emergency.