GHS

Are Your Workers Getting the Right Hazcom/GHS Training & Retraining?

Date First Published on SafetySmart Compliance: October 11th, 2012
Topics: GHS Transition | HazCom | Safety Training |

Retraining a worker to conform to GHS standards at a chemical plant

The core of the Hazcom system (as revised by the new GHS rule) is the workers’ right to know about the hazardous chemicals in their workplace. Providing workers “effective information and training” is a core element of the right to know.  And it’s not a one-time thing. You must deliver refresher and re-training at least once a year or sooner if certain conditions occur. Here’s a review of the initial and re-training rules and how to comply with them.

HAZCOM/GHS Initial Training

Normal Rule: You must provide affected workers, including not just your own employees but those of contractors exposed to hazardous chemicals at your workplace, safety information and training at the time of their initial assignment and retraining at least once a year thereafter.

2013 Rule: All affected workers must also receive training in the GHS requirements by Dec. 1, 2013, regardless of when they last received Hazcom training.

5 Things Hazcom/GHS Training Must Cover

GHS doesn’t change the substance of training. As under Hazcom, chemical safety training under GHS must cover at least 5 things:

  1. Methods and observations workers can use to detect the presence or release of a hazardous chemical in the work area;
  2. The physical hazards of chemicals in their work area;
  3. The health hazards of chemicals in their work area;
  4. Measures workers can take to protect themselves from these physical and health hazards, such as appropriate work practices, emergency procedures and PPE use; and
  5. Details of your hazard communication program, including an explanation of the workplace label system, MSDSs—which under GHS are becoming SDSs and how workers can get and use hazard information.

3 Things Hazcom/GHS Safety Information Must Cover

As with training, the substance of safety “information” required by Hazcom doesn’t change under GHS. Such information must include a description of at least 3 things:

  1. Hazcom requirements (although this description must include revisions to labels and MSDSs under GHS);
  2. Any operations in the workers’ work area where hazardous chemicals are present; and
  3. The location and availability of the written hazard communication program, including the required list(s) of hazardous chemicals and MSDSs/SDSs required.

HAZCOM/GHS Retraining

All workers exposed to hazardous chemicals must receive refresher or retraining covering the same 5 elements as initial training at least once a year. Retraining or refresher training may also be required more often if certain conditions occur. GHS changes the conditions trigger the need to provide retraining:

  • Hazcom: Retraining required whenever a new physical hazard or health hazard workers haven’t been trained on is introduced into their work area;
  • GHS: Retraining required whenever a “new physical or health hazard” for which workers haven’t received previous training is introduced into their work area. The term “chemical hazard” is defined broadly to include any chemical classified as a:
  • Physical hazard;
  • Health hazard;
  • Simple asphyxiant;
  • Combustible dust;
  • Pyrophoric gas; or
  • Hazard not otherwise classified.

Although not spelled out in the Hazcom standard or GHS rule, employers are also expected to review the adequacy of workers’ training and, if necessary, provide retraining in response to other events suggesting that current training may not be adequate to protect workers. Such red flags would include:

  • Injuries, illnesses, incidents or near misses to workers resulting from exposure to, use or proximity to hazardous chemicals;
  • Changes in procedures involving hazardous chemical(s) operations or risks;
  • Changes in equipment involving hazardous chemical(s) operations or risks;
  • Changes in location of operations involving hazardous chemical(s) risks;
  • Changes in personnel for operations involving hazardous chemical(s) risks;
  • New or current worker is assigned to a job involving hazardous chemical(s) risks; and/or
  • You become aware of significant new information about hazards posed by hazardous chemical(s) in the workplace.


Download a PDF version of this chart.

MONTHLY AT LEAST

TRIGGER

YES

NO

TASK

 [ ] Review and verify adequacy of current hazard assessment

[ ] Review and verify adequacy of current safety measures addressing hazards, including:

  1. Technological/engineering aspects
  2. Safe work procedures
  3. Supervision
  4. Training and instruction provided

[ ] Implement corrective actions in response to above

[ ] Create written documentation of above steps

Comments:

[ ] Review and verify adequacy of current hazard assessment

[ ] Review and verify adequacy of current safety measures addressing hazards, including:

  1. Technological/engineering aspects
  2. Safe work procedures
  3. Supervision
  4. Training and instruction provided

[ ] Implement corrective actions in response to above

[ ] Create written documentation of above steps

Comments:

[ ] Review and verify adequacy of current hazard assessment

[ ] Review and verify adequacy of current safety measures addressing hazards, including:

  1. Technological/engineering aspects
  2. Safe work procedures
  3. Supervision
  4. Training and instruction provided

[ ] Implement corrective actions in response to above

[ ] Create written documentation of above steps

Comments:

[ ] Review and verify adequacy of current hazard assessment

[ ] Review and verify adequacy of current safety measures addressing hazards, including:

  1. Technological/engineering aspects
  2. Safe work procedures
  3. Supervision
  4. Training and instruction provided

[ ] Implement corrective actions in response to above

[ ] Create written documentation of above steps

Comments:

[ ] Review and verify adequacy of current hazard assessment

[ ] Review and verify adequacy of current safety measures addressing hazards, including:

  1. Technological/engineering aspects
  2. Safe work procedures
  3. Supervision
  4. Training and instruction provided

[ ] Implement corrective actions in response to above

[ ] Create written documentation of above steps

Comments:

Before employee initially carries out the work:

[ ] Inform employee of:

  • Hazcom requirements;
  • Any operations in thework area where hazardous chemicals are present; and
  • Location and availability of the written hazard communication program, including the required list(s) of hazardous chemicals and MSDSs required.

[  ] Train employee in at least:

  • Methods and observations to detect presence or release of hazardous chemical in the work area;
  • The physical hazards of chemicals in the work area;
  • The health hazards of chemicals in the work area;
  • Measures employees can take to protect themselves from these physical and health hazards, such as appropriate work practices, emergency procedures and PPE use; and
  • Details of your hazard communication program, including an explanation of  labeling system, the MSDS and how employees can get and use hazard information.

[ ] Create written record documenting information and training provided

Comments:

Current employee assigned job involving hazardous chemical(s) risks

Before employee initially carries out the work:

[ ] Inform employee of:

  • Hazcom requirements;
  • Any operations in thework area where hazardous chemicals are present; and
  • Location and availability of the written hazard communication program, including the required list(s) of hazardous chemicals and MSDSs required.

[  ] Train employee in at least:

  • Methods and observations to detect presence or release of hazardous chemical in the work area;
  • The physical hazards of chemicals in the work area;
  • The health hazards of chemicals in the work area;
  • Measures employees can take to protect themselves from these physical and health hazards, such as appropriate work practices, emergency procedures and PPE use; and
  • Details of your hazard communication program, including an explanation of  labeling system, the MSDS and how employees can get and use hazard information.

[ ] Create written record documenting information and training provided

Comments:

Introduction of chemical that poses a new physical hazard or health hazard employees haven’t been trained on is introduced into their work area.

[ ] Get label from chemical manufacturer or importer

[ ] Get MSDS from chemical manufacturer or importer

[ ] Inform employee of:

  • Hazcom requirements;
  • Any operations in thework area where the new hazardous chemicals are present; and
  • Location and availability of the written hazard communication program, including the required list(s) of hazardous chemicals and MSDSs required.

[  ] Train employee in at least:

  • Methods and observations to detect presence or release of the new hazardous chemical in the work area;
  • The physical hazards of new hazardous chemical in the work area;
  • The health hazards of new hazardous chemical in the work area;
  • Measures employees can take to protect themselves from these physical and health hazards, such as appropriate work practices, emergency procedures and PPE use; and
  • Details of your hazard communication program, including an explanation of  labeling system, the MSDS and how employees can get and use hazard information.

[ ] Create written record documenting information and training provided

Comments:

Other indication or reason to believe employees may not have adequate training in chemical hazards

[ ] Verify that employee has safety training and information necessary

[ ] If the above can’t be verified:

  • Remove employee from duty that causes him to be at risk OR
  • Provide employee new, additional or refresher training in at least:

O Methods and observations to detect presence or release of the new hazardous chemical in the work area;

O The physical hazards of new hazardous chemical in the work area;

O The health hazards of new hazardous chemical in the work area;

O Measures employees can take to protect themselves from these physical and health hazards, such as appropriate work practices, emergency procedures and PPE use; and

O Details of your hazard communication program, including an explanation of  labeling system, the MSDS and how employees can get and use hazard information.

Comments:

[ ] Get revised label from chemical manufacturer or importer for hazardous chemical within 3 months

[ ] Get MSDS from chemical manufacturer or importer for hazardous chemical within 3 months

[ ] Revise the label or MSDS of the hazardous chemical if you prepared the original

ANNUALLY (AT LEAST)

TRIGGER

YES

NO

TASK

At least once a year

[ ] Review and verify adequacy of current hazard assessment

[ ] Review and verify adequacy of current safety measures addressing hazards, including:

  1. Technological/engineering aspects
  2. Safe work procedures
  3. Supervision
  4. Training and instruction provided

[ ] Implement corrective actions in response to above

[ ] Provide Hazcom refresher or retraining and safety information to any employees who haven’t received it within the past 12 months

[ ] Create written documentation of above steps

Comments:

[fbcomments]
 
 
OHS Insider
This content requires a premium membership

Forgot Your Password?