G HazCom UNDERSTANDING Hazard Communication and the Global Harmonization System S TRAINER S GUIDE
G UNDERSTANDING HazCom S Hazard Communication and the Global Harmonization System TRAINER S GUIDE EXCALVISUAL Training for EH&S Compliance 5721 Arapahoe Ave. A-2 Boulder, CO 80303 P.O. Box 19094 Boulder, CO 80308-2094 (888) 925-6554 (303) 413-0847 fax (303) 413-0683 training@excalvisual.com www.excalvisual.com LLP HC:GHSupdate-tg1401
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TABLE OF CONTENTS INTRODUCTION TO THE HAZCOM STANDARD 1 WHEN EMPLOYEE TRAINING MUST BE DONE 2 EMPLOYEES TO INCLUDE IN HAZCOM TRAINING 3 IDENTIFYING A HAZARDOUS CHEMICAL 3 HAZCOM NECESSARY INFORMATION 4 HAZCOM REQUIRED TRAINING 5 USING THE TRANSITION VERSION FOR TRAINING 6 USING THE FINAL VERSION FOR TRAINING 8 OTHER REQUIRED TRAINING 10
INTRODUCTION TO THE HAZCOM STANDARD The Occupational Safety and Health Administration (OSHA) issued the Hazard Communication (HazCom) Standard (29 CFR 1910.1200) in 1994. The Standard was amended in 2012 to make it consistent with the Global Harmonization Standard (GHS) of the United Nations. The HazCom Standard requires that all hazmat employers provide effective (emphasis added) information and training for their employees who could be exposed to any hazardous chemical known to be present in their workplace. Exposure could arise from normal conditions of use or in a foreseeable emergency. The employer may train employees on the specific hazardous chemicals present in their work areas or on classes of hazardous chemicals. This training kit, Understanding GHS HazCom, is designed to train workers on classes of hazardous chemicals. This kit includes two training videos: the transition version, for the period when GHS is being phased-in, and the final version, to be used after the transition is complete. 1
WHEN EMPLOYEE TRAINING MUST BE DONE Employers must provide employees with effective information and training on the hazardous chemicals in their work areas at the time of their initial assignment. New hires whose work will involve hazardous chemicals and current employees transferred into jobs involving hazardous chemicals must be trained before starting work. Current employees who have already been trained in compliance with the HazCom Standard as it relates to the hazardous chemicals in their work areas do not need further training. The 2012 GHS amendments state (Federal Register, Vol. 77, No. 58, pg 17638) that employers should conduct complete refresher training close to the effective date when all products have been converted to GHS-compliant SDSs and labels. This would be in late 2015/early 2016. Many employers also choose to conduct regular refresher training, often annually. 2
EMPLOYEES TO INCLUDE IN HAZCOM TRAINING Any employee who works with or around any hazardous chemical either regularly or occasionally requires HazCom training. Typically this includes some or all: Cleaning staff Maintenance employees Material handlers Production workers Processing workers Receiving personnel Stores and warehouse workers Unit operators Normally, employees who only pass through areas where hazardous chemicals are stored or used do not receive HazCom training though many employers choose to train virtually all employees. IDENTIFYING A HAZARDOUS CHEMICAL Under the GHS amendments, hazardous chemicals are defined as any chemical which is classified as a physical hazard or a health hazard, a simple asphyxiant, combustible dust, pyrophoric gas, or a hazard not otherwise classified. If the manufacturer, importer, or distributor of a substance has issued a Safety Data Sheet (SDS) on a substance or mixture of substances, it is probably a hazardous chemical. Safety Data Sheets were formerly called Material Safety Data Sheets (MSDS). 3
Consult the SDS (or MSDS) on each chemical or material used at the facility. It will describe any hazards. If no SDS (or MSDS) can be located, before assuming any chemical is not a hazardous chemical, the manufacturing, importer and distributor should be contacted. However, the substances listed below are specifically exempted from the HazCom Standard even if they meet the definition of a hazardous chemical: Articles Biological hazards CERCLA hazardous substances (being removed or remediated) Consumer products (with some exceptions) Cosmetics Drugs Food or alcoholic beverages Hazardous (RCRA) waste Nuisance particulates Radiation Tobacco or tobacco products Wood or wood products Any of these products used in the workplace (with some exceptions) do not need to be covered in the HazCom Program even if an SDS (or MSDS) has been issued. HAZCOM NECESSARY INFORMATION Necessary Employee Information: 1. The requirement for HazCom training 2. Any operations in the employee s work area where hazardous chemicals are present 3. The location and availability of the facility s written HazCom Plan 4
All affected employees must be told that their employer is required to inform and train them about hazardous chemicals to which they could be exposed at work. This includes sharing that the facility has a HazCom Plan that is available for examination. Employees should be told how to request to examine the Plan. The specific operations at their facility (or in their work areas) where hazardous chemicals are present should be identified. The location of the HazCom Plan, the complete list of hazardous chemicals and the Safety Data Sheets for all hazardous chemicals to which they could be exposed should also be provided. HAZCOM REQUIRED TRAINING Required Employee Training: 1. Methods and observations that may be used to detect the presence or release of hazardous chemicals 2. The hazards of the chemicals in the work area 3. Measures employees can take to protect themselves 4. Details of the facility hazard communication program The Understanding GHS HazCom training kit is designed to help regulated facilities provide effective training to employees on hazard communication and to comply with the revised (2012) HazCom Standard. Two HazCom training videos are included in this training kit. The Transition Version Up to December 1, 2015, both pre-ghs and GHS hazard communication methods will be in use by chemical manufacturers, importers and distributors. Suppliers are transitioning from the old to the new methods. During the transition period hazmat employees who have not already been adequately trained on the HazCom Standard can be trained on both hazard 5
communication methods. This training requirement will apply primarily to new hire employees and those who have been transfered from jobs that do not involve hazardous chemicals to jobs that do. The Final Version After December 1, 2015, employees who have not been adequately trained on the HazCom Standard must receive training. This training requirement will apply primarily to new hire employees and those who have been transferred from jobs that do not involve hazardous chemicals to jobs that do. This training will reflect only the GHS hazard communication methods. Non-GHS communication will no longer be allowed by chemical manufacturers, importers and distributors after this date. The Final Version of the kit is designed for this training. Both program versions can also be used for refresher training during the appropriate time periods. USING THE TRANSITION VERSION FOR TRAINING Prior to the training session: STEP 1: Identify all affected employees (those who could potentially be exposed to any hazardous chemical either during normal use or during a foreseeable emergency) and those that need training (or refresher training) on the HazCom Standard. This training will cover the pre- and post-ghs (unchanged and changed) requirements. Schedule a training session(s) for these employees. STEP 2: The trainer should complete the SiteCast Hazard Communication Facility Specific Training program, created with PowerPoint presentation software. The SiteCast template included 6
in the kit will guide the trainer on entering site-specific information. This will include the locations where hazardous chemicals are used at the facility. It will also include monitoring conducted at the facility (if any). The trainer may complete a single SiteCast presentation for the entire facility or, if different work areas involve different hazardous chemicals, one for each operation, work area or type of work area. In the training session: STEP 3: Provide employees with the necessary information and the required training (See pages 4 & 5 of this Trainer s Guide). Present the edited SiteCast Hazard Communication Facility Specific Training program. The trainer must narrate the SiteCast presentation and describe the content. STEP 4: Show affected employees the 23 minute video contained in the kit Understanding GHS HazCom (Transition Version). STEP 5: Answer any questions from employees. STEP 6: Administer the Transition Version Quiz. Quizzes can be printed from the training disc or copied as needed from the sheets included in the kit. Make sure each employee fills out the name and date on the Quiz sheet. STEP 7: Have employees self-grade/correct their Quizzes. STEP 8: Collect and review corrected Quizzes. Any employees whose scores are inadequate may require additional training. NOTE: The trainer may establish a passing score that he/she judges to be effective training. STEP 9: Trainers who do not wish to quiz their employees may have employees sign the Acknowledgment of Training form included in the kit to document training. File the signed Acknowledgment of Training form and/or Quizzes with the HazCom Plan or in a separate HazCom Training file. Also make and file records of any additional or remedial training performed. 7
USING THE FINAL VERSION FOR TRAINING After December 1, 2015, affected employees who have already been trained will not need to be re-trained unless a new chemical hazard is introduced into their workplace(s). However, new hire employees and those assigned from jobs that do not involve hazardous chemicals to jobs that do, will need to be trained. Prior to the training session: STEP 1: Identify all affected employees that have not received prior HazCom training. Schedule a training session(s) for these employees. STEP 2: The trainer should complete the SiteCast Hazard Communication Facility Specific Training program, created with PowerPoint presentation software. The SiteCast template included in the kit will guide the trainer on entering site-specific information. This will include the locations where hazardous chemicals are used at the facility. It will also include monitoring conducted at the facility (if any). The trainer may complete a single SiteCast presentation for the entire facility or, if different work areas involve different hazardous chemicals, one for each work area or type of work area. 8
In the training session: STEP 3: Provide employees with the necessary information and the required training (See pages 4 & 5 of this Trainer s Guide). Use the edited SiteCast Hazard Communication Facility Specific Training program. The trainer must narrate the SiteCast presentation and describe the content. STEP 4: Show affected employees the 20 minute video contained in the kit Understanding GHS HazCom (Final Version). STEP 5: Answer any questions from employees. STEP 6: Administer the Final Version Quiz. Quizzes can be printed from the training disc or copied as needed from the sheets included in the kit. Make sure each employee fills out the name and date on the Quiz sheet. STEP 7: Have employees self-grade/correct their Quizzes. STEP 8: Collect and review corrected Quizzes. Any employees whose scores are inadequate may require additional training. NOTE: The trainer may establish a passing score that he/she judges to be effective training. STEP 9: Trainers who do not wish to quiz their employees may have employees sign the Acknowledgment of Training form included in the kit to document training. File the signed Acknowledgment of Training form and/or Quizzes with the HazCom Plan or in a separate HazCom Training file. Also make and file records of any additional or remedial training performed. 9
OTHER REQUIRED TRAINING When any new hazard is introduced into a workplace after initial training, updated training will be required and should be conducted promptly. Included in the kit is a SiteCast Hazard Communication New Hazards program, created with PowerPoint presentation software. It allows the trainer to quickly create a new hazard training presentation. Prior to the final implementation date for GHS (June 1, 2016) most regulated facilities should consider re-training all affected employees. Employees should be made aware that GHS is now fully implemented and they should no longer see MSDSs or non-ghs shipping labels. Small changes like new suppliers, product name changes, and label re-design may not trigger mandatory re-training but can lead to employee confusion. Many employers prefer to refresh their HazCom training periodically, even in the absence of hazardous chemical changes. Other OSHA training related to HazCom may be required. For example, use of certain personal protective equipment (PPE) can trigger special training. This training kit includes a poster (GHS HazCom Shipping Labels Dissected) that can be placed wherever hazardous chemicals are used, stored or handled. It will remind employees how to interpret these labels and will visually explain and refresh how GHS labels communicate hazard information. Additional posters may be ordered from Excal Visual, if needed. 10
training aids include: DOT (General Awareness/Familiarization) Environmental Management Systems Environmental Awareness First Responder Awareness Level (HAZWOPER) Fuel Economy GHS Hazard Communication (HazCom) Hazardous Materials Spill Response Hazardous Waste (RCRA) for LQGs Hazardous Waste (RCRA) for SQGs Hazardous Waste (California) Hazardous Waste for Laboratories & Research Facilities Pandemic Workplace Strategies Spill Prevention Control and Countermeasure (SPCC) SPCC/ APSA for California SPCC for Electric Utilities Stormwater Pollution Prevention: Construction Sites Stormwater Pollution Prevention: General BMPs Stormwater Pollution Prevention: IDDE Stormwater Pollution Prevention: Industrial Facilities Stormwater Pollution Prevention: MS4s Municipal Facilities Universal Waste 5721 Arapahoe Ave. A-2 Boulder, CO 80303 (888) 925-6554 Fax (303) 413-0683 www.excalvisual.com Visit our website to request a free trial or to find the latest releases