The first deadline for GHS compliance was to ensure that all your workers had the required chemical safety training and information by Dec. 1, 2013. As with any other OSHA safety training requirement, simply delivering training isn’t enough. You must ensure that GHS training is effective, i.e., that workers understand and are capable of applying it. Here are 4 ways to do that.
Verification of training involves more than simply asking workers whether they understood the lesson. “Many workers will tell you that they understood even if they didn’t, either because they don’t want to seem dumb or because they want to get training over with,” explains a Syracuse, NY, GHS and chemical safety training consultation.
Workers who receive GHS training should be able to demonstrate they understood the concepts they were taught. This way, workers can’t hide what they did and didn’t absorb. Demonstrating training is also a teaching device that forces the trainee to apply the information and thus learn it more thoroughly, according to the consultant.
Example: After you provide training on the differences between the current Material Safety Data Sheet (MSDS) and the new Safety Data Sheet (SDS), give trainees actual copies of each and explain how they differ. Do the same thing with current v. new GHS chemical labels.
Have workers take a quiz like the Model Quiz in the SafetySmart Compliance Toolbox after the training session to test their understanding of GHS. Workers who don’t score a certain percentage should get additional training. Repeat the quiz a few weeks or months later to ensure that workers retain what they were taught.
You should have some form of evaluation to get worker feedback on their GHS training. There are lots of different techniques—interviews, questionnaires, focus groups and even informal chats. One common practice is to make workers fill out a Comprehension & Understanding Form.
The only sure way to determine if GHS training is effective is to observe what the workers do when they get back to the jobsite. For example, if you train workers about GHS labels and 3 days later observe them applying a chemical for a use warned against on the label, you know you have a problem and need to correct it immediately.
Always put it in writing. For each trainee, prepare a GHS Training Verification Form describing:
Keep the form in the worker’s personnel or training file and update it every time you provide additional GHS training or re-testing.[fbcomments]