Municipalities Must Take GHS-HazCom Training Seriously

The final GHS (Global Harmonization System) deadline is now long past. OSHA’s alignment of the HazCom (Hazardous Communication Standard) to GHS has provided a wakeup call to millions of companies across the U.S. to do a better job with their HazCom programs, especially when it comes to training. Unfortunately, not all Oklahoma municipalities have embraced this new standard. HazCom violations remain the number 2 violation on OSHA’s top 10 list of violations.

This article provides four steps employers can take to ensure employees understand the chemical hazards present in their work environments and to comply with GHS updates to HazCom.

  • Step One: Build a Training Program Focused on Usefulness

    • While OSHA, and here in Oklahoma, the Department of Labor’s PEOSH division don’t specify how to do training, they do state that training must be effective. Employees must carry their learning into the workplace and be able to put it to use. HazCom has two key components: 1) providing employees with a basic understanding of the HazCom standard (OMAG works with many of our cities and towns to provide this understanding.); and 2) training employees on the specific hazards of the chemicals to which they are exposed and providing protection through administrative controls, engineering controls, and personal protective equipment (These are the responsibility of the employer and its departmental supervisors.)

    • In the past, HazCom with GHS focused on training workers to understand the new SDS (safety data sheets) and labeling formats accompanied with GHS adoption. However, many employers lacked a basic level of understanding about HazCom (municipalities included), making it difficult for them to comprehend and address the changes brought by the new GHS alignment. As a result, workers were never adequately trained on HazCom in the first place or had been trained so long ago that what they learned had been forgotten. It is critical that employers continue to emphasize basic HazCom training, which now includes GHS information to ensure employees are able to use the information in their day-to-day activities.

    • The second component of an effective HazCom training program focuses on the individual hazards employees face. Departmental supervisors must train their employees on the specific chemicals used and their hazards. The key here is to provide employees with a deeper understanding of the dangers and emergency situations they face, and counter them by following written policies and procedures.

  • Step Two: Deliver Training So Employees Can Understand It

    • When OSHA first published the HazCom Standard in 1983, it followed the concept of the employee’s “right to know” about the hazards to which they might be exposed. A primary driver for OSHA’s adoption of the GHS has been the desire to improve employee comprehension of critical chemical safety information.

    • With GHS, OSHA is indicating it’s not enough for workers to just know about the hazards; instead they have the “right to understand” those hazards and know what related safety precautions to take.

    • The pre-GHS employee “right to know” concept often translated into giving workers access to MSDSs and labels and making sure they were aware of the hazards that existed from chemicals in their work environment. This approach didn’t always translate to employees understanding the safety and health information being conveyed on the MSDS and labels. GHS adoption helped solve this issue by bringing harmonization and consistency to the structure of the safety data sheets (formerly MSDS, now SDS) and labels. Use of standardized hazard communication elements, such as pictograms, make it possible for workers to more easily understand the hazards associated with chemicals workers use or are around. This simplified approach to communicating hazard information makes it possible to protect workers of all backgrounds. For instance, pictograms make it easier for illiterate and non-English speaking employees to understand the nature of a product’s hazardous properties.

    • The “right to understand” concept compliments OSHA’s rule on employee HazCom training – that it must be presented in a manner all employees can comprehend and retain. When applied to HazCom training, this means that employees who work with or around hazardous chemicals must receive training in a language they can understand, even if the documents (SDSs and labels) are only required in English.

  • Step Three: Provide Easy Access to SDSs

    • A key aspect of HazCom training is to make sure employees know how to get direct access to Safety Data Sheets (SDSs) and other hazardous chemical information. Some employers are using electronic solutions to help employees retrieve information from their inventory of SDSs. If this is true with your municipality, it is incumbent on you to make sure employees are made aware of the system, how to access it, and how to use it. Without that access, in the event of an emergency, even an employee that has received adequate training on labels and SDSs will still be at risk should a chemical event occur that requires quick action. For that reason, many employers are taking advantage of technological advancements and using mobile solutions to put SDSs in the hands of their employees. The best Environmental, Health, and Safety (EHS) software solutions today leverage the cloud to make critical chemical safety information available anywhere, any time. One problem with using technology solutions, however, is many municipalities don’t have the financial resources to provide such innovative techniques. Therefore, keeping updated SDSs available to workers in a binder within the work environment of the workers may still be the best way to provide them with quick environmental, safety, and health information when a chemical event occurs. These binders can be kept in trucks, shops, and offices - wherever the employee has access to them.

  • Step Four: Keep It Consistent

    • While OSHA and OK DOL-PEOSH don’t require employee training to be performed in specific intervals of time, regular training (at least annually) is a best practice to help ensure your employees better retain HazCom with GHS information. Other instances for training may include newly hired employees, temporary employees, visiting contract workers, or when a new chemical is introduced to a department. This helps ensure that employees who might work with or around a hazardous chemical understand its potential hazards.

It is vitally important to view HazCom and GHS training as an ongoing obligation. Over my years of travel around the state performing inspections and trainings for OMAG shareholders (cities and towns), I have personally noted frequent inadequacies with regard to HazCom and GHS training and information resources. The safety of your employees must be a priority in your day-to-day operations for their sake, for your municipality’s sake, and for the health and welfare of the state of Oklahoma.

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March 2018 Risk & Safety Newsletter

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Twelve Rules for Safe Handling of Hazardous Materials

Twelve Rules for Safe Handling of Hazardous Materials

Do your employees know how to handle hazardous materials safely? Do you have written policies and procedures for handling hazardous materials and are your employees trained on those procedures? Here are 12 basic rules all employees who handle or work around hazardous materials should know and follow:

1.      Follow all established procedures and perform job duties as you have been trained.

2.      Be cautious and plan ahead. Think about what could go wrong and pay close attention to what you are doing while working with or around hazardous materials.

3.      Always use required PPE; inspect it carefully before each use to make sure it’s safe to use. Replace worn PPE; it won’t provide adequate protection.

4.      Make sure all containers are properly labeled and that materials are contained in an appropriate container. Don’t use any chemical not contained or labeled properly. Report damaged containers or illegible labels to your supervisor immediately.

5.      Read labels and the Safety Data Sheets (SDSs) before using any material to make sure you understand hazards and precautions.

6.      Use all materials solely for their intended purpose. Don’t, for example, use solvents to wash your hands, or gasoline to clean equipment.

7.      Never eat or drink while handling hazardous material. If your hands are contaminated, don’t use cosmetics or handle contact lenses.

8.      Employees handling hazardous materials need to read labels on chemicals they use or handle and have Safety Data Sheets (SDSs) available to refer to that explain how to properly deal with handling, storing, and cleaning up spills, and that explain relevant first-aid procedures.

9.      Store all hazardous materials properly, separate incompatibles, and store in ventilated, dry, cool areas.

10.  Employees must keep themselves and the work area clean. After handling any hazardous material, wash thoroughly with soap and water. Clean work surfaces at least once per shift, so contamination risks are minimized.

11.  Learn about emergency procedures and equipment. Understanding emergency procedures means knowing evacuation procedures, emergency reporting procedures, and how to deal with fires or spills/leaks. It also means knowing what to do in a medical emergency if a co-worker is injured or overcome by chemicals.

12.  Keep emergency eyewash and shower stations clean. Test them at least monthly to make sure they are working properly and keep them accessible; don’t let clutter build up around the stations.

Your department may have other safety rules and concerns.  Present this list in a safety meeting and get your employees involved in adding to the list. This will create a sense of ownership over your safe chemical handling procedures. To the employees it will be “our procedures” rather than “their procedures” which were just given to them. If employees recognize the risks and have involvement in providing input, they will be more likely to comply with your policies and procedures.

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Noise Hazards

Public Works has many different hazards workers need to be aware of and the municipality must have procedures to ensure workers are protected.  One issue to consider is Noise Hazards.  Print the brochure below to share with your employees who may work around these hazards.

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Fall Hazards

Public Works has many different hazards workers need to be aware of and the municipality must have procedures in place to insure workers are protected.  One issue to consider is Fall Hazards. Print the brochure below to share with your employees who may work around these hazards.

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Health Hazards

Health Hazards

Public Works has many different hazards workers need to be aware of and the municipality must have procedures in place to ensure workers are protected.  One issue to consider is Health Hazards such as Lead, Silica, Asphalt, etc.  Print the brochure below to share with your employees who may work around these hazards.  

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