What are the OSHA training requirements required by December 1st for the Hazard Communication Standard (HCS)?
There are two major changes in the first phase of OSHA compliance for the revised HCS which must be completed by December 1, 2013.
As an employer in real estate and property management, the first phase of compliance requires training employees on the new label elements and the standardized format for Safety Data Sheets (SDS), formerly called Material Safety Data Sheets (MSDS).
The minimum OSHA training requirements for these two changes include the following basic information:
1. Training on Label Elements
The type of information an employee will see on new labels.
- Product Identifier: This identifies the hazardous chemical and can be the chemical name, code number, or batch number.
- Signal Word: There are only two signal words to alert the reader to a potential hazard and its relative level of severity. “Warning” is used for less severe hazards and “Danger” is used for more severe hazards.
- Pictogram: OSHA has identified eight pictograms to identify health and physical hazards. The specific pictogram requirements will be outlined in detail in the next post.
- Hazard Statements: This describes the nature of all applicable hazards and can include the degree of the hazard. Hazard statements remain the same for the same hazards, regardless of the chemical or manufacturer.
- Precautionary Statements: Describes the recommended measures of caution to take to minimize or prevent adverse effects of exposure, improper storage, or handling of a hazardous chemical.
- Name, address, and phone number of the chemical manufacturer, distributor, or importer
How an employee might use the labels in the workplace.
- For example, explain how the information on the label can be used for proper storage or to quickly locate first-aid information in an emergency.
A general understanding of how the elements work together on a label.
- For example, explain that different pictograms are used to identify various hazards for one chemical that might have multiple hazards.
2. Training on Standardized Format for Safety Data Sheets (SDS)
Information on the standardized 16-section form
- This includes the type of information found in the different sections. For example, the employee will be instructed to recognize that Section 8 contains Exposure Controls and Personal Protection information for use in exposure limits and personal protective equipment.
How the information on the label is related to the SDS.
- For example, the precautionary statements on the label and on the SDS would be the same.
OSHA Training Standards
OSHA requires employers to conduct training in a manner and language that their employees can understand. Language ability and reading comprehension must be accounted for. See Dr. Michaels’ OSHA Training Standards Policy Statement (April 28, 2010) for more information on training policy.
What Are the New OSHA Pictograms for the Revised Hazard Communication Standard?