A Primer on Hazard Communication (HAZCOM)
Basic HAZCOM training should be required for anyone who works in a facility that uses or houses chemicals.
The purpose of the Hazard Communication (HAZCOM) Standard is to ensure chemical safety throughout the workplace. Information about the identities and hazards of the chemicals must be made available and must be understood by the employees.
HAZCOM was originally called the “Employee Right to Know” standard because it established the right of employees to know the hazards from workplace chemicals to which they may be exposed. One shortfall of the original standard, however, was that employers felt justified to provide hazard information to employees without teaching employees the chemical terms and concepts necessary to understand this information.
The HAZCOM standard was most recently updated in 2012, and OSHA has just announced a proposed rule to update the Standard again as of February 2021. The current Standard requires employers to:
- Develop and implement a written HAZCOM program
- Create and maintain an inventory of chemicals used and stored in the workplace,
- Maintain and provide access to safety data sheets (SDSs) for chemicals used and stored in the workplace
- Ensure proper labeling of chemical containers with the name and hazards of the chemical
- Train employees on the standard and chemical hazards they may encounter in their daily job duties
It is important to note that HAZCOM programs, chemical inventories and safety data sheet binders are living and breathing documents. The program should not be left on a shelf to gather dust after its inception. It is vital to periodically review the program, assess the chemicals used in daily operations and modify it as often as necessary. Do not be complacent with your program!
The Hazard Communication Standard is aligned with the Globally Harmonized System of Classification and Labeling of Chemicals (GHS). This provides a universal and coherent approach to classifying chemicals and communicating hazard information on labels and safety data sheets, which improves the quality and consistency of hazard information in the workplace, making it safer for employees by providing easily understandable information on appropriate handling and safe use of hazardous chemicals. The GHS is used internationally, so OSHA’s adoption of it brings the US in line with other nations.
(Learn more about Health and Safety Symbols and Their Meanings)
Impact of Training on the HAZCOM Standard
From the inception of the Hazard Communication standard, many have failed to grasp the true extent of the necessary training. Employers have been providing employees with labels and SDSs that they could not understand. The intent of this standard is found in its nickname — “Employee Right to Know.” It is not the “Employee Right to be Told” standard. The employee needs to know (i.e., understand) the hazards of the chemicals to which they may be exposed.
That means they need to understand the chemical terms and concepts they will see on labels, SDSs and any other form of hazard warning they may encounter during their jobs. In fact, with the changes in the GHS standard, the nickname for “Right to Know” has been updated to “Right to Know and Understand.” Many employers have squeaked by OSHA compliance officers without teaching employees everything necessary for them to truly understand what labels and SDSs say, but those employers certainly have not made their employees safer.
Who Needs HAZCOM Training?
The short and simple answer to this question is everyone. While that may sound like a daunting task as an employer, every employee — even those who never leave their office desk — should receive at least the most basic, awareness-level training. The reality is nearly every employee will come across a chemical in the workplace at some point, and it is important that they know and understand the associated hazards.
For those employees who encounter workplace chemicals as a daily part of their job routine, they should receive further in-depth training. OSHA states that:
Employers shall provide employees with effective information and training on hazardous chemicals in their work area at the time of their initial assignment, and whenever a new chemical hazard the employees have not previously been trained about is introduced into their work area.
All employees should receive hazard communication training when any hazard or hazard information pertinent to their work area changes. No employer should risk the ethical and liability failures of having information that could have prevented an injury, but not providing that knowledge to the employees who need it.
Refresher training should be conducted as new hazardous materials are introduced into the workplace. Employees should learn of the potential hazards before they are used. If, for example, the newly introduced cleaning agent is a corrosive substance, and there has never been a severe corrosive hazard in the workplace before, then new training for corrosive hazards must be conducted for the affected employees. If, on the other hand, a new cleaning agent is introduced into the workplace, and it has similar hazards to an existing cleaning agent for which training has already been conducted, then no new training is required.
What a Comprehensive Hazard Communication Training Program Should Cover
A comprehensive Hazard Communication training program should first outline the frequency of the training. Training should be conducted:
- As part of onboarding training for new hires
- As refresher training any time an employee demonstrates a lack of the knowledge necessary to work safely with hazardous chemicals
- At least annually as a refresher
- Any time when a hazard or hazard information pertinent to the employee’s work area changes
The topics of a comprehensive Hazard Communication training program should include:
- The types of operations in work areas where hazardous materials are present
- Where the written HAZCOM program is located, its availability, the content provided in the program and its requirements
- The location and availability of any hazardous materials that are in your inventory
- The location and availability of SDSs, how to read them and where to find the most important information, such as personal protective equipment (PPE) requirements and first-aid procedures
- The methods employees can use to detect the presence or release of toxic chemicals, such as the color or smell
- Alarm or warning systems that employees may hear in the event of a release, and how to properly react
- The existence of any monitoring programs, such as environmental or medical
- The hazards associated with the chemicals, such as physical and health hazards
- Engineering controls, safe work practice guidelines, emergency procedures and PPE available to protect employees from the hazards in their work areas
- Thorough explanations of the labeling system used in the facility and the methods employees can use to obtain hazardous chemical information
The length of training will be based on the current knowledge of the employees working with the chemicals; however, it is important not to breeze over topics simply because it has been discussed before. Generally, training should be between one and four hours for most workplaces. Included at the end of the training should be a form of written test to verify competency. Ideally, training should be performed by instructors who have at least two years’ experience in adult training methodologies, and in addition, they must be knowledgeable about handling the hazardous materials on which they are training.
Do you want to ensure your managers and training personnel are properly educated on the Hazard Communication Standard? We suggest enrolling in the Hazard Communication Specialist course offered by the National Association of Safety Professionals. This IACET-accredited 13-hour/1.3 CEU course is sure to cover the bases. Readers can save 10% off the course tuition with code SAFEHCS10.