GHS at a Glance

GHS Training Requirements

Date First Published on SafetySmart Compliance: November 25th, 2013
Topics: GHS Transition | HazCom |

OSHA’s Final GHS Rule officially took effect last year on May 25, 2012. The first deadline for employers: Provide GHS training to employees by December 1, 2013. Here’s a quick overview of GHS training requirements.

HOW GHS CHANGES HAZCOM TRAINING REQUIREMENTS

Chemical safety information and training requirements are set out in Sec. 1910.1200(h) of the Hazcom standard. As before, you must provide employees “effective information and training” on hazardous chemicals in their work area. But GHS changes the substance and timing of training requirements.

Who Must Be Trained

Any employee that required safety information and training under previous rules must receive it under GHS, i.e., any worker exposed to chemical hazards while performing jobs at your facility. As before, this includes not just your own employees but those of outside contractors or subcontractors. Although you don’t have to actually provide training yourself, you must ensure that such training has been provided before the employee/worker performs the job involving exposure.

Who Can Provide Training

As before, chemical safety training must be delivered by a person(s) who’s knowledgeable about:

  • The particular hazardous chemicals used, handled or stored at your workplace;
  • The requirements of Hazcom and GHS; and
  • The provisions of your company’s written Hazard Communication Program (HCP).

What GHS Safety Information Must Cover

As before, hazardous chemical safety information must cover:

What GHS Safety Training Must Cover

As before, hazardous chemical safety training must cover:

  • The methods and observations that may be used to detect the presence or release of a hazardous chemical in the work area;
  • The measures employees can take to protect themselves from chemical hazards, including specific procedures implemented by the employer to protect employees, e.g., work practices, emergency procedures and PPE; and
  • The details of the employer’s hazard communication program, including how to access MSDS/SDSs.

GHS also revises the information chemical safety training must cover, as summarized in this chart:

EMPLOYEES/WORKERS MUST BE TRAINED ABOUT:

PREVIOUS RULE

NEW RULE

 “physical and health hazards” of chemicals in their work area

 “physical, health, simple asphyxiation, combustible dust and pyrophoric gas hazards, as well as hazards not otherwise classified” of chemicals in their work area

workplace labeling system

workplace labeling system and labels themselves

 how to access and use MSDS information

how to access and use SDS information, including order of information listed on SDS

When Chemical Safety Training Must Be Provided—Initial GHS Training By Dec. 1, 2013

The most important training requirement in GHS is the obligation to ensure that all employees exposed to hazardous chemicals and who require Hazcom training also receive GHS training by December 1, 2013, covering:

  • How to read the new GHS workplace labels;
  • How to access and use SDSs, including the order of information listed in the SDS; and
  • How to protect themselves from physical, health, simple asphyxiation hazards, combustible dust, pyrophoric gas hazards and hazards not otherwise classified

When Chemical Safety Training Must Be Provided—Ongoing Training & Re-Training

Before, employees/workers had to receive new chemical safety training whenever a new “physical or health hazard” for which they hadn’t received previous training was introduced to their work area. Under GHS rules, new training is required when new “chemical hazards” for which no previous training has been provided are introduced into their work area. “Chemical hazard” is a broad definition that includes any chemical classified as a:

  • Physical hazard;
  • Health hazard;
  • Simple asphyxiant;
  • Combustible dust;
  • Pyrophoric gas; or
  • Hazard not otherwise classified.

Conclusion

December 1, 2013 is not so far in the future. You need to start making plans now to deliver GHS training. And you might not have the luxury of time if the chemical manufacturers and suppliers have completed re-classification and prepared GHS labels and SDSs ahead of schedule. After all, if you got GHS labels and SDSs in your workplace now, you better be darned sure your employees know how to use them.

 
 
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