The hazard communication system (HCS) regulations are covered in 29CFR1910.1200. Subsection (h) provides requirements for employee information and training. Right off the bat, OSHA makes it clear that a dog and pony show in lieu of actual training is not acceptable. They do this by using the word “effective” [1910.1200(h)(1)]. This training must cover the hazardous chemicals in the employees’ work area at the time of their initial assignment and whenever a new hazardous chemical (one they have not been previously trained about) is “about to be introduced.” Notice those last four words — the training must precede the introduction of the chemical. That is, people must be trained before the chemical is in their work environment.
One mistake some employers make is scheduling HCS training (for example, quarterly) and catching up on whatever training is missing due to changes from the previous training session. OSHA will cite you for this. Even worse, an untrained employee may be badly injured to due lack of timely training. So, make sure to get the timing right.
What information must you provide employees? This is laid out in 1910.1200(h)(2)(i) through (iii):
- The requirements of 1910.1200.
- Any operations in their work area where hazardous chemicals are present.
- The location and availability of the written HCS. This includes the lists of hazardous chemicals and the safety data sheets.
What training must you provide employees? This is laid out in 1910.1200(h)(3)(i) through (iv):
- Methods and observations that may be used to detect the presence or release of a hazardous chemical.
- The physical health, simple asphyxiation, combustible dust, and pyrophoric gas hazards along with other hazards not otherwise classified. This requirement applies to all of the chemicals in the work area.
- How employees can protect themselves.
- The details of the HCS.
As you can see, that training covers a lot of ground. Be sure to allow for sufficient time to cover it, noting that training counts only if it is effective.
In many cases, it is cost effective to hire a training consultant to review your HCS and conduct the appropriate training. The reason that can be cost-effective is a qualified consultant will tend to make the training process very efficient and thus you pay out far less in labor hours to complete the training. If the consultant specializes in HCS training, she or he most likely already has a proven system and merely needs to incorporate your particulars. If you go this route, be sure the consultant can also train two or three people who can conduct the advance training needed when a new chemical is about to be introduced.
