Employee training is a vital part of your hazard communication program. We
urge you as an employer to view the hazard communication process
as an opportunity to improve the safety and health of your employees,
and to conduct your training in a way that motivates your employees
to work safely. If you approach the training program as a means
to enhance worker protection rather than as another burdensome requirement
imposed by government, you may enjoy some positive results: less
absenteeism, a reduction of lost time accidents, a reduction of
work related illnesses, a possible reduction in Workers' Compensation costs, and potentially, saved lives.
These guidelines were developed to aid employers in complying with Maryland's Right-to-Know
Law. The guidelines are not intended as a substitute for the law
but rather are offered as suggestions to employers who must develop employee training programs.
Specific legal requirements are detailed in 29 CFR 1910.1200(h), Employee Information and
Training. You should use that information in conjunction with these guidelines.
WHEN TO TRAIN
- Initial training is required for all employees
- New employees must be trained before their first assignment.
- Additional training is required whenever:
- new hazards are introduced into the workplace,
- exposure to hazardous chemicals changes,
- employees are subject to increased exposure due to changes in work practices,
processes or equipment, or
- additional information about the hazardous substances in the workplace becomes available.
TRAINING PROGRAM
A. Prepare Objectives
Identifying specific learning objectives is the first step in establishing an effective
training program. Right-to-Know training should be designed
to provide information and training on six key points. These are:
- The purpose and content of the law,
- The nature of the hazardous substances in the workplace,
- Protection from the hazards,
- How to obtain information on hazardous materials used in the workplace,
- How to use the information on hazardous materials, and
- Employee rights.
B. Determine Who to Train
- Identify the employees to be trained.
Using such tools as organizational charts, employee rosters
and personnel records, identify the groups of employees who
must be trained. Within one workplace, there may be such diverse
staff as secretarial, managerial, engineering, production, maintenance, and sales staff.
- Consider employees’ exposure to hazardous substances.
After identifying the groups of employees who must be trained,
assess the employees' actual and potential exposure to hazardous
chemicals, both during normal conditions of use and in potential
emergencies. The program must provide detailed information to
those employees who are using the chemicals. For those employees
who may be exposed to a chemical only in a foreseeable emergency,
training in identifying and responding to the emergency should
be provided. For emergency training, also consult the requirements
of 29 CFR 1910.120 Hazardous Waste Operations and Emergency Response.
- Identify how employees are hired and transferred between jobs.
Determine the best method to ensure that employees are appropriately
trained and updated. How employees are hired may determine the
most appropriate manner to train new employees before their
initial assignment. Perhaps the Right-to-Know training can be
integrated into an orientation program or existing safety and
health training. If employees frequently are transferred to
different jobs, the training program should provide information
for each type of exposure that may occur.
C. Design the Training Program
Keeping your objectives and employees in mind, begin to develop a program that meets
the needs of your particular operation. While the nature and
complexity of processes will vary from company to company, there
are certain requirements that all employers must meet in order
for a training program to be effective:
- An explanation of what the law is about.
Explain that the purpose of the law is to create a safer and
healthier workplace by providing employees with information
about the chemicals they use. Provide a brief overview of the
law explaining that it contains definitions of hazardous materials
as well as requirements for chemical information lists, data
sheets, labeling, written hazard communication programs, and
training. Tell your employees what you, as an employer, have
done to comply with the law, such as compiling a chemical information
list, obtaining material safety data sheets, and conducting training.
- An explanation of how the chemicals in the workplace can be a hazard.
Explaining the hazards of chemicals in the workplace is a vital
part of your training program. A first step in developing this
portion of your program is evaluating the information about
the hazardous chemicals on the labels and material safety data
sheets. This may be an ideal time to organize the information
so it is work area specific and is readily accessible in each work area.
This portion of the training should provide information on the specific nature
of operations involving hazardous chemicals, a description of
physical and health hazards of the materials, and when appropriate,
a discussion of any signs or symptoms of overexposure. Emphasize
hazardous chemicals that may be formed as a by-product of a
process (for example, carbon monoxide from burning L.P. gas).
Provide specific information to help employees recognize and
evaluate conditions and situations that may result in employee exposure.
- A discussion of how exposure to hazardous chemicals
can be controlled. Include both routine and emergency
situations such as a major leak or spill. The discussion should
provide information on such topics as:
- Work practices ¾ procedures for handling materials, steps to minimize exposure,
prohibitions on consumption of food and beverages in areas of possible contamination.
- Engineering controls ¾ ventilation, process control equipment, remote sensors, etc.
Be sure to explain when and how these controls are to be used.
- Personal protective equipment ¾ gloves, goggles, respirators, protective clothing,
etc. Be sure to discuss the proper usage, storage, maintenance,
and limitations of any protective equipment, as well as its location and availability.
- An explanation of how employees can obtain information on hazardous substances.
Describe your written hazard communication program and the system
that you use to make chemical information lists and material
safety data sheets (MSDS) available to employees. Employees
should understand exactly when, where, how, and from whom they
can obtain access to the written hazard communication program,
the chemical information list, and material safety data sheets.
Explain any labeling, posters, or placarding systems that you use to convey hazard information.
- An explanation of how to use information on hazardous substances.
- Labels ¾ Train employees in the importance of reading labels. Explain the types
of warning labels an employee may expect to see and discuss the importance of following directions.
There are commercially available labeling systems that use methods other than text
to convey hazard warnings. Some of these systems use pictographs,
icons, or color coded numerical warnings to describe the degree
of hazard and required personal protection equipment. Many of
the suppliers of these materials also can provide audio-visual
aids for employee training. Personal computer software can generate
"appropriate hazard warning" labels based on keyboard
entry of the name of the substance. While relatively simple
to use, the software does require a computer, a printer and basic computer skills.
- MSDS¾ Training also must focus on the material safety data sheets and how employees
can use them as a tool to find answers to their questions about
specific materials. It is more important to ensure that each
employee has a basic knowledge of how to find information on
the sheet and to properly make use of that information than
to review every MSDS with each employee. One approach is to
use graphics such as slides, view graphs or posters of typical
material safety data sheets to provide a section-by-section explanation.
- An explanation of employee rights.
Tell employees and their designated representatives that
they have three basic rights under the Right-to-Know law:
- Ready access to material safety data sheets, upon request,
- Access to the chemical information list within one working day of a request, and
- One copy of the requested information or the means to produce a copy, without
charge, within five working days.
If an employer fails to provide the required access to or a copy of the information
about the hazardous chemical, the employee may refuse to work with the hazardous chemical.
D. Select Techniques for Training
Consider the following ideas as you begin to develop your training plan:
- The person or persons designated to do the training should be credible, respected,
and knowledgeable about the operations and should be given the
time, authority, and resources to develop an effective program.
- All employees may be trained at one time in some aspects of the law, while
some individuals or small groups may need special instructions.
- Training may be conducted in a formal classroom setting or informally in "tool
box" sessions, if appropriate.
- Posting additional information in certain work areas may reinforce some aspects of your training.
- Handout materials that reinforce portions of the program may be useful.
- The use of audiovisual materials such as videotapes and sound/slide presentations may
be helpful for discussion of a topic such as the use of material
safety data sheets. A number of vendors supply these materials.
A review of advertisements in safety and health literature.
Be sure to review training materials before purchase to assure
they meet the requirements of the Maryland law and your specific needs.
- Check with your professional society or trade association. Many of these groups
have training materials. Some are geared to specific industries.
- Demonstrations are valuable training aids. Issues such as proper selection
and use of personal protective equipment and simulated spill
cleanup lend themselves to demonstrations. Some vendors provide
training that you may wish to incorporate into your program.
- Periodic retraining is an important part of an effective training and education
program. Retraining should be provided at least annually. Additionally,
the principles discussed in your training should be reinforced
on a regular basis when the chemicals are being used.
E. Assess Effectiveness
At the conclusion of a training session, it is important to evaluate its effectiveness.
The following suggestions may be helpful:
- Determine if the training objectives were met. This can be done by testing. You
may wish to use a written test, a one-on-one oral evaluation
with employees, or demonstration by employees of skills learned from the training.
- Stimulate discussion by presenting hypothetical situations and asking for comments.
- Provide an opportunity at the end of each training session for questions and answers.
- Ask for employees’ evaluation of the training. Try to determine what employees
found most valuable and helpful and what they found least useful.
You can use this information in planning subsequent training
sessions. If it is clear that the training did not give the
employees the expected level of knowledge and skill, it may
be necessary to revise the training program and provide retraining.
F. Establish Procedures for Recordkeeping
In the event of a MOSH inspection, a record of training can help prove that adequate
training was provided. As a minimum, records should include:
- Who was present (you may want to use a sign-in sheet)
- Who conducted the training
- A brief outline, summary or lesson plan of what was covered
- The date the training was conducted
- The length of the training
- Titles of any audiovisual material used
G. Note What is Not Considered "Training"
While audiovisual materials, notices to employees, and posters may be valuable as
training aids, merely providing them does not constitute adequate
training. The following are examples of what would NOT be considered adequate training:
- Distributing or reading material safety data sheets to employees without any
explanation of how to interpret them.
- Showing a generalized slide/tape program on Right-to-Know without determining if it
meets all the training requirements outlined in the Maryland law.
- Posting a notice to employees without providing an explanation.
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