Question: What is proper Hazcom training?
Answer: Let’s look at the different aspects:
When Training Must Be Provide: Employees must be trained at the time they’re assigned to work with a hazardous chemical. The point of the rule (1910.1200(h)) is to ensure the employee gets the information before he/she’s exposed. So training after exposure is no good.
Form of Training: Just giving employee the data sheets to read isn’t enough. An employer’s training program must be a forum for explaining to employees not only the hazards of the chemicals in their work area, but also how to use the information generated in the hazard communication program. This can be accomplished in many ways (audiovisuals, classroom instruction, interactive video), and should include an opportunity for employees to ask questions to ensure they understand the information presented to them.
Scope of Training: Training need not be conducted on each specific chemical found in the workplace, but may be conducted by categories of hazard (e.g., carcinogens, sensitizers, acutely toxic agents) that are or may be encountered by an employee during the course of his duties.
Qualify of Training: Training must be comprehensible. If the employees receive job instructions in a language other than English, then the training and information to be conveyed under Hazcom also needs to be conducted in a foreign language.
See Also: OSHA Instruction CPL 2-2.38D, Inspection Procedures for the Hazard Communication Standard, 29 CFR 1910.1200, 1915.99, 1917.28, 1918.90, 1926.59, 1928.21; Appendix A, CLARIFICATIONS AND INTERPRETATIONS OF THE HAZARD COMMUNICATION STANDARD (HCS).