Properly Train or Pay the Fine?

Properly Train or Pay the Fine?

Employees need to understand the hazards that are in their workplace.  The Employer must give them training and the proper equipment to protect them from these hazards.  I cannot count the number of businesses I have visited where the company training consists of reading the “MSDS book” over there on the shelf. 

The first indication that training is NOT occurring or has been updated, is the term MSDS (Material Safety Data Sheets) on the binder.  This term was replaced under the new GHS (Globally Harmonized System) rules with SDS, or Safety Data Sheets.  Additionally, the hazard symbols on materials are changed with new meanings and icons.

What is considered proper training under the HAZCOM standard?

The requirements for training (1910.1200(h)) are available online.  It states that employees are to be trained at the time they are assigned to work with a hazardous chemical.   This does not mean to wait until a spill occurs and have them read the information in the SDS.

Employees need to have information prior to exposure to prevent the occurrence of adverse health effects. OSHA rules state that “training provisions of the HCS are not satisfied solely by giving employee the data sheets to read”.

The training must explain the hazards of chemicals in their work area, but also how to use the information generated in the hazard communication program. Examples can include:

  • Audiovisuals

  • Classroom instruction

  • Interactive video

  • Web-based Training

and should include an opportunity for employees to ask questions to ensure that they understand the information presented to them. One method of ensuring learning transfer to the employee is to end the instruction with a test or quiz.

This training should cover the chemicals encountered by employees in the workplace.  If the company works with a lot of different chemicals, employees should understand the safety requirements for each of the categories of hazard (e.g., carcinogens, sensitizers, acutely toxic agents) that are or may be encountered on the job.

The last requirement for training is the employees ability to comprehend the instruction.  Employers must provide the instruction in a language that matches how employees receive  job instructions. 

Penalty Case – OSHA cited a power systems company for six violations, including two willful violations, due to injuries to multiple workers which included chemical burns to the skin and irritation to their respiratory tracts requiring urgent medical treatment. The workers were injured after exposure to an acid mixture while cleaning a spill that occurred at the facility. The company was cited for failing to provide workers with required protective equipment to prevent exposure and failure to provide required training in hazardous material clean-up procedures. The citations carry proposed penalties of $166,000.

OSHA stated that the company "showed a complete disregard for the health and safety of its workers when they made them perform a cleanup of a dangerous chemical without providing them with required training and protective gear, …these employees were needlessly injured because this company was more interested in a fast cleanup than protecting the people who work for them."

OSHA has cited two willful violations for directing employees to respond to an acid spill without conducting a hazard evaluation, lack of personal protective equipment and failing to train workers in emergency response procedures.

The company was also cited for four serious safety violations including failing to develop an emergency response plan; provide decontamination and first aid treatment for responders; and provide respiratory and personal protective equipment for use during cleanup.

We recommend a blended approach to Hazard Communication training.  Initial training through is inexpensive and easy to track employee completions.  With these basics completed a short follow-up explanation for in-house information can complete the requirements for general and localized training.  While the citations above included clean-up operations a complete Hazard Communication program could have prevented the exposure all together.





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