Training Requirements & Topics Of Chemical Hazards
Training Requirements
Employees must receive information and training that ensures their awareness of the chemical hazards in their work area. Employers must also provide this information when an employee is initially assigned to a work area where hazardous chemicals are present before assignments involving new exposure situations.
Employees must be informed of the following:
- the requirements of the HCS 2012
- any operations in their work area where hazardous chemicals are present
- the location and availability of the written hazard communication program (including the required list(s) of hazardous chemicals and SDSs required by the HCS)
To ensure all training requirements are met, we recommend reviewing each section of the SDS. Group discussion and examples can be effective training strategies to make the training more interesting to students. Demonstration and practice using PPE for properly using and cleaning up spills are especially important.
Training Topics
Training Topics Information and training may be designed to cover categories of hazards (e.g., flammability, carcinogenicity) or specific chemicals. Chemical‐specific information must always be available through labels and SDSs.
Employee training must include at least the following:
- Methods and observations that may be used to detect the presence or release of a hazardous chemical in the work area.
- The physical, health hazards, simple asphyxiation, combustible dust, and pyrophoric gas hazards, as well as hazards not otherwise classified, of the chemicals in the work area.
- The measures employees can take to protect themselves from these hazards, including specific procedures the employer has implemented to protect employees from exposure to hazardous chemicals, such as appropriate work practices, emergency procedures, and personal protective equipment to be used.
- The details of the hazard communication program developed by the employer includes an explanation of the labels received on shipped containers and the workplace labeling system used by their employer; the safety data sheet, including the order of information and how employees can obtain and use the appropriate hazard information
Training at Multi‐Employer Worksites
The training requirements also apply if the employer becomes aware via the multi‐employer worksite provision of exposures of his/her employees to hazards for which they have not been previously trained.
Training Temporary Employees
Training temporary employees is a shared responsibility between the host employer and the temporary agency.
- Host Employer: The host employer is responsible for training on the company’s HCS program requirements, including specific labelling, chemical hazards and safe work procedures in their workplace.
- Temporary Agency: The temporary agency, in turn, maintains a continuing relationship with its employees and would be expected to inform employees of the requirements of the HCS standard.
Contracts between the temporary agency and the host employer should be examined to determine if they clearly set out the training responsibilities of both parties to ensure the employers have complied with all requirements of the regulation.
Training for Emergencies
A frequently overlooked portion of the training provisions is dealing with emergency procedures. The scope and extent of employee training depend on how much the employer plans to respond to emergencies. The HCS training program may need to include the HAZWOPER Emergency Response Plan and/or the Emergency Action Plan as follows:
- Suppose the employer merely intends to evacuate the work area. In that case, the training in emergency procedures could be limited to, information on the emergency alarm system in use at the worksite, evacuation routes, and reporting areas as detailed in the employer’s Emergency Action Plan under 1910.38, Emergency Action Plans.
- Where employees are expected to moderate or control the impact of the emergency like an emergency responder, training on an Emergency Response Plan as described in 1910.120(l), Hazardous Waste and Emergency Operations (HAZWOPER), would be required.
