Training is the heartbeat of hazcom compliance. If an OSHA inspector thinks your employees are not trained properly, he’s probably ask to go over your entire hazcom program. Last year (FY 2010), hazard communication was OSHA’s 3rd most frequently cited standard.
OSHA’s flexible with HOW you train. OSHA isn’t too specific on the format of your hazard communication training so you can use audiovisuals, classroom instruction, and interactive video if you want. You can also provide training by category of hazard, such as carcinogens or toxic agents, instead of by specific chemical.
You don’t have to train on every chemical. Training is required for new physical or health hazards, not for every new chemical that enters the workplace. BUT, if a newly introduced chemical doesn’t fit into a category you’ve already trained on, you will have to provide training for that new chemical.
You have to be sure your employees understand the training—even if they don’t speak English. According to OSHA regulations, you must train your workers in a language that they will understand. Use this as a guideline—train your workers in the language they use to receive job instructions.
You don’t have to document your training—but you should. It’s not required to prove that you’ve provided hazard communication training but like most OSHA training topics it makes sense to keep good records on it. Here’s a tip, don’t just keep a class attendance list, document what was taught in the class and how well it was achieved.
