Hazard Communication Training Model
This document is designed to help employers provide effective training to employees who are exposed to hazardous chemicals, as required by the Occupational Safety and Health Administration's (OSHA) Hazard Communication Standard (HCS). Effective training is vital to understanding the information provided on chemical container labels and material safety data sheets, and applying that information in the workplace to protect against chemical hazards.
This guidance document provides a description of a suggested approach to training employees about chemical hazards. OSHA recognizes that many employers may not have the need for as comprehensive a training program as would result from implementation of all of the elements presented in the Model Training Program. The Agency hopes that such employers will find the portions of the Model Training Program that apply to their workplace to be useful.
This document is advisory in nature and informational in content. It does not alter or determine compliance responsibilities, which are set forth in the Hazard Communication Standard (29 CFR 1910.1200) and in the Occupational Safety and Health Act. Moreover, because interpretations and enforcement policy may change over time, the reader should consult current administrative interpretations and decisions by the Occupational Safety and Health Review Commission and the courts for additional guidance on OSHA compliance requirements. Paragraph (h) of the HCS addresses employee information and training. The requirements reflect the overall purpose of the standard. Some key words and phrases have been underlined:
a. First, employers should 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 physical or health hazard that employees have not been previously trained about is introduced into their work area. Information and training may be designed to cover categories of hazards (such as flammability or carcinogenicity) or specific chemicals. Chemical-specific information must always be available through labels and material safety data sheets.
b. Second, employees shall be informed of:
- The requirements of this section;
- Any operations in their work area where hazardous chemicals are present;
- The location and availability of the written hazard communication program, including the required list of hazardous chemicals, and material safety data sheets required by this section.
c. Third, employee training shall include at least:
- Methods and observations that may be used to detect the presence or release of a hazardous chemical in the work area (such as monitoring conducted by the employer, continuous monitoring devices, visual appearance or odor of hazardous chemicals when being released, etc.);
- The physical and health hazards of the chemicals in the work area;
- The measures employees can take to protect themselves from these hazards, including specific procedures the employer has implemented to protect employees from exposure to hazardous chemicals, such as appropriate work practices, emergency procedures, and personal protective equipment to be used; and
- The details of the hazard communication program developed by the employer, including an explanation of labels and material safety data sheets, and how employees can obtain and use the appropriate hazard information.
What should I do first? It is often necessary to prioritize hazard communication information and training needs. If you are responsible for a simple operation, using only one or two hazardous chemicals, it is not too difficult to plan your HCS information and training program. This is particularly true if your employee turnover is low. Employers, however, often use many different chemicals in their operations, and frequently hire new employees or transfer existing employees to new jobs. It is then necessary to prioritize training activities.
Prioritizing Hazard Communication Training First, use existing company records to define groups potentially exposed to hazardous chemicals. Next, review previous training history.
How do I identify training needs? Once you have made some general plans about training priorities, it is important to zero in on specific training needs. You need to diagnose the training task, and figure what types of learning are pertinent for effective results. There are three areas to consider.
1. Task Analysis - What jobs are involved? What kinds of learning are appropriate?
2. Population Considerations - What are the characteristics of your workforce? For example, what are the educational levels and work experience of the employees?
3. Resource Considerations - What resources are available? For example, do you already have some training materials that could be used in the hazard communication training?
How do I prepare training goals and objectives? Hazard communication training programs, like any other activity, are more effective if planned in detail. On-target programs that focus on precise and measurable objectives will be successful in meeting the requirements of the standard; unplanned and unfocused programs will not. OSHA, in the Voluntary Training Guidelines, defines three elements of a learning objective:
1. Performance must be observable. Employees must be able to demonstrate what they have learned.
2. Performance must be measurable. The objective should define what constitutes acceptable performance.
3. Conditions in which performance is to occur must be stated. Objectives should describe the important conditions under which the individual will demonstrate competence.
How do I put a program together? Once you know what the learning objectives are, you can plan learning activities. There are several characteristics of hazard communication training to keep in mind. All the trainees are adults, who have different training needs and preferences than children in an educational setting. Within the total group, there may be wide differences in education and job experience, as we discussed earlier. Because we want the knowledge and skills acquired in training to be transferred to the job situation, you need to consider the sequencing of training to match up with job activities as much as possible. You have to make decisions about methods and media, based on the training needs and resources that you have identified and the objectives that you have defined. Lastly, you must view training as a continuing process, rather than a "one-shot" deal, so that the safe work practices and hazard communication knowledge are maintained on the job.
Selection of Methods and Media. We know that training is most effective when it simulates the actual job as closely as possible. The closer the simulation, the easier it is for the worker to transfer knowledge and skills to the job. a. Sequencing training activities. It is therefore a good idea to arrange the objectives and training activities in a sequence that corresponds to the order in which the tasks are to be performed on the job. For example, if an employee is to learn the process of responding to a hazardous chemical leak or spill, a skill activity, the proper actions should be taught in the same order. Various training approaches, in order of descending effectiveness, are as follows:
- The real thing (for example, handling a real label or protective equipment);
- A simulation (for example, practicing the handling of simulated chemical spills using water or other harmless agents);
- Audiovisual representation (for example, a videotape showing a spill being handled);
- Visuals (such as pictures of appropriate protective equipment);
- Lectures; and
- Handouts.
Handouts appear at the bottom of the list because there is no certainty that they will be studied or even opened when they are the only training approach. As supplements, however, handouts can be very valuable for purposes of reference and reminder. These can be useful tools for all health and safety training.
Conducting Training. How you conduct training will, of course, depend upon the initial assessment of needs and the population and resource considerations that you have identified. Most hazard communication training will be addressed to issues specific to each workplace and will be conducted at the local level with small groups of employees. Time is usually available only in "chunks" of not more than 40 minutes, or the time normally devoted to a regular safety meeting. In any circumstances, the four activities involved in conducting training are overview, presentation, application, and practice or review.
How do I evaluate program effectiveness? Many instructors think that they are through with their hazard communication training when they are finished with the training sessions. However, it is extremely important to gain an idea of whether the program is effective. It is more important where the HCS is concerned than for any other standard, since it is a "performance" standard. Program effectiveness is judged by whether it achieves its objectives and actually works. The information that you will gain from evaluation will be very useful, since you will be able to make changes that continually improve the effectiveness of the training. As a simple example of an easy-to-measure objective, either the employees will know where the emergency shower is, or they will not. Similarly, either employees will be able to follow correct evacuation procedures or they will not, and either they will be able to locate important information on the MSDS or they will not. Without an evaluation, you cannot know if training has been successful or has been completely off-target, nor will you know how to correct any problems.
Generally, evaluations are either formative or summative. Formative evaluations measure success during or immediately following training development and implementation; they tell the instructor what needs to be done immediately to improve the training. Summative evaluations measure whether the knowledge or skills have transferred to the job and other long-term results.
To help set up your program, OSHA has prepared lesson plans. The Lesson Plans are: General Elements for All Employees--A. Understanding the Hazard Communication Standard B. Understanding the Material Safety Data Sheet C. Understanding Labels D. Understanding Health Information. General Elements---Chemical Information---E. Flammables and Combustibles F. Corrosives G. Reactive Chemicals H. Toxic Chemicals. Lesson are found on the OSHA website at www.osha.gov. The first page of each Lesson Plan lists the lesson title; the intended audience; any prerequisites; the approximate time required; materials and equipment needed, and learning objectives.
Reprinted with permission. © CCH
Hazard Communication Training Model. This document is designed to help employers provide effective training to employees who are exposed to hazardous chemicals, as required by the Occupational Safety and Health Administration...
Hazard Communication Training Model
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