I’ve prepared detailed briefings about the new GHS rules for my workers to read. Do I have to provide Spanish translations for the workers who don’t speak English?
— Name withheld
As you know, the deadline to provide GHS training to workers was December 1, 2013. The GHS regulations don’t go into details about what language training materials must be delivered in but we know from longstanding practice that OSHA training on any topic isn’t compliant unless all workers can understand it.
So handing out training materials in a language your workers don’t speak won’t pass muster.
In fact, OSHA recently issued guidance on GHS training that spells this out. According to the guidance, employers must present GHS “information in a manner and language that their employees can understand.”
The rule of thumb: “If employers customarily need to communicate work instructions or other workplace information to employees in a language other than English, they will also need to provide safety and health training [including on GHS] to employees in the same manner.”
And here’s one more thing to consider: Simply handing the materials to your English-speaking workers may also be inadequate to comply with your GHS training requirements to the extent any of those workers are illiterate.
At the end of the day, your obligation is not simply to deliver but verify that your workers actually understand their GHS training.
Let me know what’s on your mind and I’ll do my level best to give you some answers and practical guidance. firstname.lastname@example.org.