Employees are to be trained at the time they are assigned to work with a hazardous chemical. The intent of this provision (1910.1200(h)) is to have information prior to exposure to prevent the occurrence of adverse health effects. This purpose cannot be met if training is delayed until a later date. The training provisions of the HCS are not satisfied solely by giving employee the data sheets to read. An employer’s training program is to 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 that they understand the information presented to them. 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. Furthermore, the 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 the HCS will also need to be conducted in a foreign language.
Reference Interpretation and Compliance Letters:
- The employer must provide the 1910.1200 verbal training in a language that is comprehensible. [04/10/88]
- Training required for clean-up of hazardous waste and hazardous substances. [06/10/91]
- 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).
October 2018
Tags: HAZCOM, OSHA
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