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OSHA HAZARD COMMUNICATION STANDARD INFORMATION

OUTLINE OF AN OSHA HAZARD COMMUNICATION TRAINING PROGRAM:

KNOW THE PROVISIONS OF THE HAZARD COMMUNICATION STANDARD

• Be familiar with the requirements of the standard
• Know your responsibilities under the law
• Inform all employees of the law and their rights under the law.

IDENTIFY THOSE EMPLOYEES TO BE TRAINED

• Assess actual and potential employee exposure to hazardous chemicals
• Determine training needs based on this exposure during both normal use of hazardous chemicals and during emergencies.
• Determine appropriate ways in which to train new employees and supervisors
• Train employees and supervisors on the specific chemicals in your workplace and their hazards.

KNOW THE HAZARDOUS CHEMICALS IN YOUR WORKPLACE

• Define hazardous chemicals: Any chemical that is a physical or health hazard.
• "Physical hazard" is one for which there is scientifically valid evidence that the chemical is a combustible liquid, a compressed gas, an explosive, a flammable substance, an organic peroxide, an oxidizer, a pyrophoric, or an unstable (reactive) or water-reactive substance.
• "Health hazard" is one that includes cancer-causing, toxic or highly toxic agents, reproductive toxins, irritants, corrosives, sensitizers, hepatotoxins, nephrotoxins, neurotoxins, agents that act on hematopoietic system, and agents that damage the lungs, skin, eyes, or mucous membranes. (See Appendices A & B of the Standard for more information on this.)

MAKE A LIST OF THE HAZARDOUS CHEMICALS IN YOUR WORKPLACE

• Your list should include the names of the chemicals, their hazards, any protective measures to be taken, and emergency and first-aid procedures.
• Identify the process or operation where the chemicals are used, and the name and address of the manufacturer.
• Make sure there is a material safety data sheet (MSDS) for each chemical and that the list references the corresponding MSDS for each chemical.
• Make the list readily available to your employees (or to other employers at your worksite at their request).
• Make sure employees understand the information regarding the chemicals listed in the workplace.

INSTRUCT EMPLOYEES ON HOW TO USE AND INTERPRET MSDS's

• Make sure you have an MSDS for each hazardous chemical product you package, handle, or transfer.
• Check each MSDS you receive to ensure that it contains all the information required by the standard.
• Obtain MSDS's or information where necessary (i.e., when MSDS not received from manufacturer, importer or supplier, or when MSDS is incomplete.

INSTRUCT EMPLOYEES ON LABELING

• Check each container entering the workplace for appropriate labeling (i.e., identity of chemicals, hazard warnings; name and address of manufacturer/importer/responsible party).
• Explain the importance of reading labels and of following directions for the safe handling of chemicals.
• Label, tag, or mark containers into which hazardous chemicals are transferred with the chemical identity and hazard warnings.
• Hazard warning must convey specific physical and health hazards of the chemicals. Explain that words such as "caution," "danger," "harmful if absorbed by skin," etc. are precautionary statements and do not identify specific hazards.
• Explain the labeling exemptions for portable and stationary process containers.
• Label portable containers when they are not for "immediate use." (Note: Portable containers require no labels when chemicals are transferred into them from labeled containers and when the chemicals will be used immediately by the employee transferring the chemicals.)
• In lieu of labels, process sheets, batch tickets, standard operating procedures, or other written materials may be used on stationary process equipment if they contain the same information as a label and are readily available to employees in the work area or station.
• Cross-reference chemical identifiers on labels to MSDS's and the lists of hazardous chemicals.
• Be aware of other hazardous chemicals that may have specific labeling requirements under other standards (e.g., asbestos, lead, etc.).

REVIEW EXISTING METHODS OF CONTROLLING WORKPLACE EXPOSURES

• Engineering Controls: changes in machinery, work operations, or plant layout that reduce or eliminate the hazard (e.g., ventilation controls, process enclosures/hoods, isolation, etc.).
• Administrative Controls: good housekeeping procedures, safe work practices, personal and medical monitoring, shortened shifts or changed work schedules, etc.
• Personal Protective Equipment: safety glasses, goggles, face shields, earplugs, respirators, gloves, hoods, boots, and full body suits.
  • REVIEW YOUR CURRENT PROCEDURES FOR HANDLING CHEMICALS AND COMPARE WITH

    RECOMMENDED PRACTICES IDENTIFIED ON MSDS's AND LABELS **

KEEP A RECORD OF EMPLOYEE/SUPERVISOR TRAINING

• Follow-up and evaluate your training program to make sure employees know how to handle the chemicals they are using and are applying the training you have given them.

ESTABLISH A WRITTEN EMERGENCY ACTION PLAN

• Training in procedures such as emergency controls and phone numbers, evacuation plans, alarm systems, reporting and shut-down procedures, first-aid, personal protection, etc.
• How and when to report leaks and spills.

OSHA HAZARD COMMUNICATION STANDARD - TRAINING GUIDELINES

MATCHING TRAINING TO EMPLOYEES

While all employees are entitled to know as much as possible about the safety and health hazards to which they are exposed, and employers should provide all relevant information and instruction to all employees, the resources for such an effort frequently are not, or are not believed to be, available. Thus, employers are often faced with the problem of deciding who is in the greatest need of information and instruction and then addressing those training needs first.

One way to differentiate between employees who have priority needs for training and those who do not is to identify employee populations which are at higher levels of risk. The nature of the work will provide an indication that such groups should receive priority for information on occupational safety and health risks.

IDENTIFYING EMPLOYEES AT RISK

One method of identifying employee populations at high levels of occupational risk (and thus in greater need of safety and health training) is to pinpoint hazardous occupations. Even within industries which are hazardous in general, there are some employees who operate at greater risk than others. In other cases the hazardousness of an occupation is influenced by the conditions under which it is performed, such as noise, heat or cold, or safety or health hazards in the surrounding area. In these situations, employees should be trained not only on how to perform their job safely but also on how to operate within a hazardous environment.

A second method of identifying employee populations at high levels of risk is to examine the incidence of accidents and injuries, both within the company and within the industry. If employees in certain occupational categories are experiencing higher accident and injury rates than other employees, training may be one way to reduce that rate. In addition, thorough accident investigation can identify not only specific employees who could benefit from training but also identify company-wide training needs.

Research has identified the following variables as being related to a disproportionate share of injuries and illnesses at the worksite on the part of employees:

1. The age of the employee (younger employees have higher incidence rates).
2. The length of time on the job (new employees have higher incidence rates).
3. The size of the firm (in general terms, medium-size firms have higher

   incidence rates than smaller or larger firms).

4. The type of work performed (incidence and severity rates vary

   significantly).

5. The use of hazardous substances (by SIC Code).

These variables should be considered when identifying employee groups for training in occupational safety and health.

TRAINING EMPLOYEES AT RISK

Determining the content of training for employee populations at higher levels of risk is similar to determining what any employee needs to know, but more emphasis is placed on the requirements of the job and the possibility of injury. One useful tool for determining training content from job requirements is the Job Hazard Analysis. This analysis examines each step of a job, identifies existing or potential hazards, and determines the best way to perform the job in order to reduce or eliminate the hazards. Its key elements are (1) job description; (2) job location; (3) key steps (preferably in the order in which they are performed); (4) tools, machines and materials used; (5) actual and potential safety and health hazards associated with these key job steps; and (6) safe and healthful practices, apparel, and equipment required for each job step.

CHECKLIST FOR OSHA HAZARD COMMUNICATION TRAINING PROGRAM:

                                                             YES        NO
                                                           =================

 1. Have you established a thorough training program?      ______     ______

 2. Does it identify employees who need training?          ______     ______

3. Does the training program ensure that new

employees are trained before their first assignment? ______ ______

4. Does The Training Program Inform Employees Of:

1. The specific information and training

   requirements of the Hazard Communication Standard? ______ ______

2. The requirements of the standard, and their

   rights under the law? ______ ______

3. The written program and training requirements? ______ ______
4. The different types of chemicals and the hazards

   associated with them? ______ ______

5. Specific hazards of the chemicals and processes

   they work with and their proper use and handling? ______ ______

6. The hazards associated with performing nonroutine

   tasks? ______ ______

7. Do employees know how to detect the presence or

   release of hazardous chemicals in the workplace? ______ ______

8. Did The Training Program:
9. Train employees in the use of proper work

   practices, personal protective equipment and clothing, and other controls to reduce or eliminate their exposure to the chemicals in their work areas? ______ ______

10. Train employees in emergency and first-aid

    procedures and signs of overexposure? ______ ______

11. List all the hazardous chemicals in our

    workplace? ______ ______

12. Do employees know when and how to update our

    hazardous chemical list? ______ ______

13. Have you obtained or developed a material safety

    data sheet for each hazardous chemical in the workplace? ______ ______

14. Did The Training Program explain how to use an

    MSDS? ______ ______

15. Did The Training Program inform employees of the

    list of hazardous chemicals and MSDS's and where they are located? ______ ______

16. Did it explain labels and their warnings to

    employees? ______ ______

17. Have You:
18. Developed a system to insure that all incoming

    hazardous chemicals are checked for proper labels and data sheets? ______ ______

19. Established procedures to ensure proper labeling

    or warnings signs for containers that hold hazardous chemicals? ______ ______

20. Developed a way to identify and inform employees

    of new hazardous chemicals before they are introduced into a work area? ______ ______

21. Established a way to inform employees of new

    hazards associated with the chemicals they already use? ______ ______

22. Developed a way to evaluate the effectiveness

    of the training program and to keep track of who has received training? ______ ______

SOURCE: Hazard Communication - A Compliance Kit, by U.S. Department of Labor, Occupational Safety and Health Administration, 1988, OSHA 3104.

Additional information concerning the OSHA Hazard Communication Standard can be found by searching PENpages using the keyword OSHA.

          FARM-MANAGEMENT, HAZARD-COMMUNICATION-STANDARD, HAZARDOUS, HEALTH,
          OCCUPATION, OSHA, REFERENCE, SAFETY, STANDARD, TRAINING, WORKPLACE

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%f TITLE;OUTLINE - OSHA
%f COLLECTION;FARM AND OPERATOR SAFETY
%f ORIGIN;Pennsylvania
%f DATE_INCLUDED;June 1992