During the many years I was an EHS regulatory consultant, and then a Global EHS Coordinator of a large manufacturing company, I evaluated many facilities for compliance with OSHA’s Hazard Communication (HazCom) Standard and saw a lot of issues with both the content and management of their HazCom training programs. Often, the causes of those issues were misconceptions about key general aspects of HazCom discussed in training, or about regulatory requirements concerning training itself.
Time and time again, I witnessed the damage that these misconceptions did to employee awareness of workplace HazCom practices and employer responsibilities under the Standard. This is especially concerning because, since the publication of the 2012 final rule that updated the Standard to align with Revision 3 of the UN’s Globally Harmonized System of Classification and Labelling of Chemicals (GHS), OSHA has emphasized that employees have a Right to Understand (RTU) the basic aspects of HazCom most relevant to them, and that employee understanding is the proof that employers have fulfilled their training obligations. Given that OSHA published a proposed rule to update the Standard to align with GHS Revision 7 in 2021, and may issue a final rulemaking before the end of 2022, employee understanding of HazCom, and the urgency to get training right, are more important than ever.