Written Hazard Communication Program.
Very important, but, don't be intimidated by this requirement of the standard.
The written program need not be lengthy or complicated, yet it is likely to be one of the first things an OSHA inspector will ask to see during an inspection.
The written hazard communication program needs to be specific to your workplace, and it must describe the methods the employer will use to inform employees of the hazards involved in routine as well as non-routine tasks performed.
The written program must outline the procedures the employer will use to meet the requirements for Hazard Communication as follows: MSDS - how they are addressed & used in the workplace.
Labeling Practices - of hazardous chemicals and substances you work with, including any other form of warnings (such as signage for hazardous areas or conditions).
An Inventory List of Chemicals - that are used at your workplace and jobsites, identified as they are referenced on the appropriate material safety data sheet (you may compile the list for the workplace as a whole or for individual work areas).
In Multi-Employer Worksites - the method the employer will use to provide the other employer(s) all precautionary information or measures that need to be taken to protect those employees (if exposed) from hazards such as; the production, use, or storage of hazardous chemicals or conditions present, and likewise when an employer will be working in your area.
Training in the methods, practices, and observations which employees are to use in the recognition of actual and (or) potential health hazards, andmeasures they should take to protect themselves and others.
Ongoing and updated training sessions provided by the employer must also provide to the employee a clear understanding of the overall "HazCom" program and their role in it.
Employee Training.
Training of your employees in all areas of Hazard Communication in your business on a regular basis is critical to the success of the entire program.
The requirements regarding training are as follows: Employers shall provide to their employees information - by means of training on hazardous chemicals/ situations in their work area[s] at the time of their initial assignment, and whenever a new hazard is introduced into their work area.
The hazard communication standard - and it's requirements must be addressed as part of employee training.
Employees shall be informed of the location and availability - of the written "HazCom" program, including the required list of hazardous chemicals, and MSDS applicable to their work area(s) or job sites.
MSDS - proper usage, understanding, and availability must be covered as part of their training.
Each employee shall be trained - in the methods and observations that may be used to detect the presence or release of a hazardous chemical, including the physical and health hazards of those chemicals in their work area.
The measures employees should take - to protect themselves, including procedures the employer has implemented to protect employees from such hazard exposure, for example, appropriate work practices, emergency and evacuation procedures when applicable, and personal protective equipment to be used.
The details of the "HazCom" program - developed by the employer, an explanation of the labeling system and material safety data sheets, multi-employer worksite procedures, and how employees can find and use the appropriate information.
In a situation where employees are exposed to a small number of chemicals in the workplace, the employer may discuss the particular hazards of each one.
Where there are large numbers of chemicals, the training regarding hazards could be done in categories (e.
g.
, flammable liquids, carcinogens, etc.
).
Either method would be acceptable.
In either case, the employees are to be referred to information on product labels and MSDS.
Re-training shall occur when - the hazard changes, not just when a new chemical is introduced into the workplace.
If the new chemical has hazards which employees have been previously trained about, then no re-training is required.
If the chemical has a hazard they have not been trained about, then re-training is necessary but limited to that hazard.
Note: Employee training should include all areas of your "HazCom" program including the written program.
Make sure each employee has received a complete copy and has read and clearly understands it.
Note:Document your training sessions regardless of the duration, list the employee name(s), date, time, place, subject or topic covered etc.
, and have each employee in attendance sign-off on an attendance sheet.
Keep these records for future reference and as a guide for on-going training periods and subject matter.
Very important, but, don't be intimidated by this requirement of the standard.
The written program need not be lengthy or complicated, yet it is likely to be one of the first things an OSHA inspector will ask to see during an inspection.
The written hazard communication program needs to be specific to your workplace, and it must describe the methods the employer will use to inform employees of the hazards involved in routine as well as non-routine tasks performed.
The written program must outline the procedures the employer will use to meet the requirements for Hazard Communication as follows: MSDS - how they are addressed & used in the workplace.
Labeling Practices - of hazardous chemicals and substances you work with, including any other form of warnings (such as signage for hazardous areas or conditions).
An Inventory List of Chemicals - that are used at your workplace and jobsites, identified as they are referenced on the appropriate material safety data sheet (you may compile the list for the workplace as a whole or for individual work areas).
In Multi-Employer Worksites - the method the employer will use to provide the other employer(s) all precautionary information or measures that need to be taken to protect those employees (if exposed) from hazards such as; the production, use, or storage of hazardous chemicals or conditions present, and likewise when an employer will be working in your area.
Training in the methods, practices, and observations which employees are to use in the recognition of actual and (or) potential health hazards, andmeasures they should take to protect themselves and others.
Ongoing and updated training sessions provided by the employer must also provide to the employee a clear understanding of the overall "HazCom" program and their role in it.
Employee Training.
Training of your employees in all areas of Hazard Communication in your business on a regular basis is critical to the success of the entire program.
The requirements regarding training are as follows: Employers shall provide to their employees information - by means of training on hazardous chemicals/ situations in their work area[s] at the time of their initial assignment, and whenever a new hazard is introduced into their work area.
The hazard communication standard - and it's requirements must be addressed as part of employee training.
Employees shall be informed of the location and availability - of the written "HazCom" program, including the required list of hazardous chemicals, and MSDS applicable to their work area(s) or job sites.
MSDS - proper usage, understanding, and availability must be covered as part of their training.
Each employee shall be trained - in the methods and observations that may be used to detect the presence or release of a hazardous chemical, including the physical and health hazards of those chemicals in their work area.
The measures employees should take - to protect themselves, including procedures the employer has implemented to protect employees from such hazard exposure, for example, appropriate work practices, emergency and evacuation procedures when applicable, and personal protective equipment to be used.
The details of the "HazCom" program - developed by the employer, an explanation of the labeling system and material safety data sheets, multi-employer worksite procedures, and how employees can find and use the appropriate information.
In a situation where employees are exposed to a small number of chemicals in the workplace, the employer may discuss the particular hazards of each one.
Where there are large numbers of chemicals, the training regarding hazards could be done in categories (e.
g.
, flammable liquids, carcinogens, etc.
).
Either method would be acceptable.
In either case, the employees are to be referred to information on product labels and MSDS.
Re-training shall occur when - the hazard changes, not just when a new chemical is introduced into the workplace.
If the new chemical has hazards which employees have been previously trained about, then no re-training is required.
If the chemical has a hazard they have not been trained about, then re-training is necessary but limited to that hazard.
Note: Employee training should include all areas of your "HazCom" program including the written program.
Make sure each employee has received a complete copy and has read and clearly understands it.
Note:Document your training sessions regardless of the duration, list the employee name(s), date, time, place, subject or topic covered etc.
, and have each employee in attendance sign-off on an attendance sheet.
Keep these records for future reference and as a guide for on-going training periods and subject matter.