Inform and Train Employees

Paragraph (h) of the HCS requires that employers train employees on the hazardous chemicals in the workplace before their initial assignment and when new hazards are introduced.^2,4 The training must be conducted in a manner and language that the employees understand. The standard requires employees to be informed of (1) the general requirements of HazCom 2012, (2) where hazardous chemicals are located, and (3) the various elements of the HazCom program.

Workers must have a general understanding of what information is provided on labels and SDSs, and how to access them. If there are only a few chemicals in the workplace, each one may be discussed individually. Where there are large numbers of chemicals, training may be designed to cover categories of hazards. Workers must be made aware of the protective measures available, how to use or implement these measures, and who they should contact if an issue arises.

1. Training on label elements

   1. Employees should be advised of the type of information that they can expect to see on the labels

      1. Product identifier

         1. How the hazardous chemical is identified. This can be (but is not limited to) the chemical name, code number or batch number.

         2. How to cross-reference the product identifier with the SDS of the product, i.e., the same product identifier must be both on the label and in Section 1 (Identification) of the SDS.

      2. Signal word

         1. Explain that signal words are used to indicate the relative level of severity of hazard and to alert the employee to a potential hazard on the label.

         2. Explain that there are only two signal words, “Danger” and “Warning.” Within a specific hazard class, “Danger” is used for the more severe hazards and “Warning” is used for the less severe hazards.

         3. Explain that only one signal word will appear on the label no matter how many hazards a chemical may have. If one of the hazards warrants the signal word “Danger” and another warrant the signal word “Warning,” only “Danger” will appear on the label.

      3. Pictogram(s)

         1. Explain that OSHA-required pictograms must be in the shape of a square set at a point and include a black hazard symbol on a white background with a red frame wide enough to be clearly visible.

         2. Explain that OSHA has designated eight pictograms under this standard for application to a hazard category.

         3. Explain that when a chemical has multiple hazards, the label will contain a pictogram for each hazard category.

      4. Hazard statement(s)

         1. Discuss the nature and degree of the hazard(s). For example: “Causes damage to kidneys through prolonged or repeated exposure when absorbed through the skin.”

         2. Explain that all applicable hazard statements appear on the label and employees should always see the same statement for the same hazards, no matter what the chemical is or who produces it.

      5. Precautionary statement(s)

         1. Explain that precautionary statements describe recommended measures to minimize or prevent adverse effects resulting from exposure to a hazardous chemical.

      6. Name, address and phone number of the chemical manufacturer, importer, or distributor

      7. How an employee might use the labels in the workplace

         1. Explain how the information on the label might be used to quickly locate information on first aid when needed by employees or emergency personnel.

         2. Explain how information on the label can be used to ensure proper storage and disposal of hazardous chemicals.

      8. How the various elements work together on a label

         1. Explain that labels display pictograms appropriate for each hazard class, i.e., when a chemical has multiple hazards, different pictograms identify the various hazards.

         2. Explain that when there are similar precautionary statements, the one providing the most protective information will be included on the label.

2. Training on the format of the SDS

   1. Explain the standardized 16-section format, including the type of information found in the various sections

      1. For example, the employee should be instructed that with the SDS format, Section 8 (Exposure Controls/Personal Protection) will always contain information about exposure limits, engineering controls and ways to ensure protection, including personal protective equipment.

   2. Explain how the information on the label is related to the SDS

      1. Explain that the same product identifier appear both on the label and in Section 1 of the SDS (Identification).

      2. Explain that the precautionary statements are the same on the label and on the SDS.

Employee Information and Training for Hazards of Non-routine Tasks

While workers’ initial training addresses the types of exposures likely to be encountered in their usual work routines, there may be other tasks to be performed on occasion that will expose these workers to different hazards that may require novel control measures. Paragraph (e)(1)(ii) mandates that employees be informed of the hazards of non-routine tasks.^2,4 The written program must to address how the employer will handle such situations to ensure that the workers have the necessary information to stay protected.