Employee training is one of the 5 key pillars to OSHA’s Hazard Communication standard here in the United States. But what do you need to do? How often do you need to train? What training content should be provided? What’s the most effective means of training workers for both quick understanding, but also long-term knowledge retention? These are the questions that most often come to mind.
Employees have a right not to get hurt at work and employers have a responsibility to take every reasonable measure to provide a safe work environment. Not every hazard or incident can be prevented, but some core training and continuing education will make your facility a safer place to work.
Chemicals present an unusual set of safety concerns and requirements. Chemicals can be unpredictable, are not always in a fixed location and, in some cases, can be incompatible to other chemicals in the immediate work environment. Therefore, chemical safety training must occur early, often and as close or specific to the actual location and usage scenario as possible.
Be In The Know
Prior to embarking on your chemical safety training, you should have a chemical safety program defined and in place. Safety data sheets, the primary form of chemical information, are becoming increasingly dense with detailed technical information. Consequently, some basic employee protections and precautions can get lost in translation. Therefore, it’s imperative that your training efforts refocus back to the original goal of the SDS, which is to help and protect workers.
OSHA requires organizations that store or use hazardous chemicals in the workplace address five key requirements for chemical safety:
- Written Program
- Chemical Inventory
- Safety Data Sheets
- Chemical Labels
- Employee Training
Employee training is listed last, not as a ranked order of importance, but rather a statement to the fact that the other four elements are prerequisites of an effective chemical safety training program. OSHA defines a hazardous chemical is any chemical that poses a physical or health hazard. Physical hazards are chemicals for which there is scientifically valid proof that it is a combustible liquid, a compressed gas, flammable, an organic peroxide, an oxidizer, pyrophoric, water reactive, or is otherwise unstable (reactive). Health hazards are chemicals for which there is statistically significant evidence that acute or chronic health effects may occur in exposed employees. This includes chemicals which are carcinogens, toxic or highly toxic agents, reproductive toxins, irritants, corrosives, sensitizers, hepatotoxins, nephrotoxins, neurotoxins, agents which act on the hematopoietic system, and agents which damage the lungs, skin, eyes, or mucous membranes.
These requirements and definitions provide the foundation for how you should define your chemical management plan and chemical safety training program.
Your Chemical Safety Training Guide
Your chemical safety training program should offer the following core information: Chemical inventory listing, standard operating procedures for the use of chemicals in the workplace, safety data sheet and labeling information, specific chemical risks in your facilities, precautions and emergency response procedures, storage, disposal and transportation considerations and training resources and requirements. Let’s consider these in a bit more depth:
Chemical inventory listing – this should either contain a listing of the chemicals in your facility or instructions on how to access the inventory if you are using another format to publish chemical information, such as an online SDS management system. The listing should be maintained on a periodic basis, ideally through an annual physical chemical inventory to account for additions, subtractions and disposals. Furthermore, the listing can and should be used to reconcile to safety data sheets made available to employees.
Chemical SOP (Standard Operating Procedures) – this would include general guidelines on the usage of and presence of chemicals in the workplace. Some specific SOP include: following company chemical approval processes, understanding the hazards prior to usage, ensuring that you are outfitted with all recommended PPE prior to usage, not working alone with working with hazardous substances, avoiding direct contact with hazardous substances, and having a general understanding of exposure systems for the chemicals in your area and be mindful if you experience any of those conditions
Safety data sheet (SDS) – your training should outline where to find SDS and how to read them. If using an online SDS system, make sure that you provide clear operating instructions and training on that system. This is typically the most effective way to publish chemical information and provide access as these systems offer multiple methods to access chemical information – either directly from the safety data sheet or from indexed data that can should be searched directly, such as PPE, emergency response, etc.
Labeling – chemical containers must include a label outlining the product name, manufacturer, signal words, hazards, precautionary statements and pictograms. Train your workers on how to read these labels, especially the visual pictograms.
Specific facility risks – you might have specific chemical risks in your facilities due to the nature of your business or industry. You might have higher volumes of certain chemicals or maybe more hazardous substances. It’s always a good idea to emphasize these and even specifically identify these in your training plan for extra attention and education. For example, identifying chemicals by particular hazards, such as flammable, carcinogens, volatile/reactive, combustible, etc. is always a good idea.
Precautions and emergency response procedures – what are the standard precautions and emergency response procures for your facility? What PPE is required? Where can it be accessed? Where are emergency eyewashes, showers, exits, etc. in the event of a chemical spill, exposure or emergency? What is the evacuation plan? Your chemical training plan should address these facility-specific questions to ensure maximum protection.
Storage, disposal and transportation considerations – define the storage requirements for hazardous chemicals or refer to the specific instructions per the chemical label. Ensure that employees are aware of potentially incompatible chemicals that exist in your facility or chemicals with specific storage requirements.
Training resources and requirements – provide easy access information so workers know where to get more information. There is a lot to communicate with chemicals, so it’s important to reinforce any periodic training with on-demand training and resources for specific instances that an employee may face while working. This could be in the form of on-demand, mobile training on their phones so they can review safety precautions prior to working with a chemical. It may also include posters with emergency response information that detail how to access safety data sheets or call an emergency response line in the event of a chemical exposure or spill.
Put It Into Practice
So how do you implement the training plan and what are some best practices for chemical safety training? First, combining both instructor-led training and online training is a good way to reinforce concepts repeatedly for your workforce. As noted above, chemical information can be overwhelming at times, so offering repeatable, bite-size concepts repeatedly is often the best way to handle employee training. This is known as “micro-learning” – focus on smaller, more defined concepts in an on-demand environment so the student learns and retains the key learning concepts.
Additionally, make your training global and local – offer general training and information related to chemical safety as a whole, but also deliver location-specific, chemical-specific and hazard-specific training for individual locations or employees working with extremely hazardous substances. Consider a “connected compliance” approach. If you have your chemical/SDS management system on the same platform as your training, you can more easily match employees, chemicals and chemical risks by location to deliver the right training to the right employee at the right time.
Regarding timing and frequency, it’s recommended that workers receive training regarding the physical and health hazards of the chemicals in their work area at the time of their initial assignment to the work area, whenever a new chemical hazard is introduced into the work area or annually as part of a coordinated workplace safety training effort.