Violations of OSHA’s hazard communication (Hazcom) standard have been among the top three general industry citations for the past decade. One of the top citations within the Hazcom standard is failure to provide adequate training.
OSHA’s adoption of Globally Harmonized System of Classification and Labeling of Chemicals (GHS) in 2012 renewed the focus on Hazcom and forced everyone to revisit their existing plans and protocols, including training. Deadlines were established for training employees on the new pictograms, signal words, precautionary statements and other labeling elements as well as how to access information on standardized Safety Data Sheets (SDS).
With the adoption of GHS came the aspiration that employees would be better able to understand and protect themselves from hazards in their workplaces. As it has been since the inception of the Hazcom standard in 1983, employers were tasked with educating their employees and helping them to gain that understanding.
Reasons for OSHA violations
OSHA is very clear about the need for Hazcom training to be effective. In fact, this is where many of the citations for failure to provide training originate. Facilities do provide training, but it is proven to be ineffective because employees can’t demonstrate what they’ve learned. It is not enough to simply present the information. There needs to be a method of gauging that that information has been understood and can be applied.
Studies in adult learning show that adults do not retain much of what they are told during a lecture. Adults also do not generally retain much of what they read. However, when they are able to practice a skill or teach it to someone else, they are much more likely to actually learn and retain what they have been taught.
Incorporating actionable tasks into Hazcom trainings helps employees better apply what they have been taught. It will helps foster a greater understanding of how this information benefits them and helps them to be safer at work.
Get your people involved
Each employee has unique life experiences that could be used to reinforce a safety message. During daily or weekly safety meetings, give employees the opportunity to use these experiences to teach each other. Adults learn more when they are involved in the learning process and when they can share what they have learned with others.
As employees become more comfortable sharing experiences and teaching small concepts, they will be able to take responsibility for that knowledge and be better able to apply it to their work.
Adults need to understand how training applies to their situation. They need to understand how what they are being taught benefits them. Instead of just hanging a poster of the eight GHS pictograms, use it as a visual aid during safety stand ups. Have eight people choose one of the pictograms and explain how the engineering controls or personal protective equipment that is used onsite helps to protect them from whatever harms are expressed by that particular pictogram.
Containers as learning props
Classroom learning is quickly lost if employees aren’t able to apply what they have learned. One way to do this when teaching Hazcom is to stage a work area with unlabeled or improperly labeled containers.
The containers should be familiar items that are used daily in the workspace. A goal is for the employees to recognize that the containers are not properly labeled and to be able to point out what elements are missing. For example, the bottle needs a signal word. They don’t necessarily need to know what signal word is needed—just the fact that the bottle needs that labeling element.
Training can be expanded to include an explanation of why labeling every container is important and the consequences of using the wrong chemical in a given application. For employees who don’t like to take written tests, being able to identify missing label elements and describe what is needed is a method that can be used to demonstrate their knowledge without requiring a traditional pen-and-paper test.
Use safety data sheets as a tool
Chances are good that even if each of the 16 sections of a safety data sheet (SDS) were discussed in great detail, that information is not going to be retained. And, even though the new standardized format makes it easier to find the information you need about a chemical, most people aren’t going to be inclined to pick up a SDS binder when they want to do a bit of pleasure reading.
Not all employees need to become SDS experts, but it is important for all to understand what types of information a SDS provides. Use SDS as a tool in daily or weekly trainings. Give everyone a copy of two or three SDS. Have them find the first aid information in each SDS. Have them compare flashpoints or pH levels.
Incorporate hazcom into other safety trainings
Hazard communication is an essential part of employee safety. Instead of viewing it and other required safety trainings as their own books, view each as a chapter in a large novel. With this mindset, Hazcom principles can be woven into other required trainings.
The purpose of OSHA’s adoption of the GHS standard is to increase understanding and improve safety when working with hazardous chemicals. By moving Hazcom training out of the classroom and providing practical applications for this knowledge, employees will be better able to apply what they have been taught and better embrace OSHA’s vision for enhanced safety.