Millions of employees are exposed to hazardous chemicals each year, and without the proper precautions in place and adequate training, severe injuries or death can occur. The Occupational Safety and Health Administration (OSHA) recently revised its Hazard Communication standard to adopt the Globally Harmonized System of Classification and Labelling of Chemicals (GHS). To help organizations navigate HazCom requirements, Cintas Corporation debunks six popular HazCom/GHS myths.
“With the HazCom standard’s GHS training requirement now in effect and the New Year in full swing, many organizations are scrambling to train workers and determine what requirements they will face next, while others still are unclear if GHS applies to their business,” said Tom Lally, Director of Training and Compliance, Cintas. “By debunking myths associated with HazCom and GHS, we can make chemical safety compliance much clearer before the Occupational Safety and Health Administration comes knocking for an inspection.”
1. Only people using chemicals need to undergo training
Many organizations are still struggling to understand their responsibilities with regard to HazCom training. Training is required for any employee who will be exposed or potentially exposed to chemicals under normal workplace conditions. People who are only “occasionally” in the vicinity of chemicals are exempt from the rule. For instance, if employees periodically use a chemical to clean the kitchen sink, they will not need to complete training. However, if the job requires multiple sinks to be cleaned, or if a CEO conducts plant tours where chemicals are present, this is considered routine exposure and training is required. Even shippers or handlers who are sending hazardous chemicals to businesses that will use the materials must undergo training. If it’s unclear whether employees need to be educated about hazardous chemicals, organizations should conduct training to be safe.
2. Temporary workers don’t need to be trained.
On the contrary, OSHA is making a big push to ensure organizations train temporary employees properly. Oftentimes employers solely focus on educating full-time employees or assume that temp agencies have trained outside contractors. However, there are certain details that temp agencies can’t prepare these workers for, such as the location of Safety Data Sheets (SDS). Organizations should work closely with the temp agency to make sure the necessary training occurs to guarantee safety.
3. HazCom violations won’t break the bank.
OSHA bases violations on the seriousness of the offense, ranging from general to serious/willful. The average fee per violation will likely be $900-1100, although OSHA is considering increasing the fees to encourage better compliance. If a chemical-related injury or death occurs, an organization will face severe fines and brand perception issues if employees were not properly trained. However, organizations should view compliance as a way to protect workers, not simply a method for avoiding fines.
4. HazCom violations occur infrequently.
HazCom violations are actually frequently included in OSHA’s top 10 violations each year. Preliminary estimates for 2013 ranked HazCom violations second with 6,156 incidents and once all data is collected, this number is expected to rise due to noncompliance with GHS guidelines. Workplaces are often cited because of 1) a lack of a written plan 2) inadequate employee training and 3) unavailability or inaccessibility of SDS sheets. All impacted employees should be properly trained and have direct access to SDSs.
5. Current chemicals must be disposed of because they lack the proper labels.
Although the training deadline has passed, the deadline for applying new chemical labels will not arrive until June 2015. This gives organizations time to use up current chemicals and reorder new inventory. These new shipments will arrive in containers with the revised labels. Employers should wait for the chemical manufacturer or distributor to provide the new labels rather than labeling containers themselves. This is a complicated process and doing it incorrectly can create financial and safety liabilities.
6. All HazCom/GHS training is the same.
Not all training is created equal and employers must ensure they provide effective education. It’s best to offer a blended approach that relies on DVD, online and instructor-led courses in multiple languages. Training should be continuous, rather than a one-time occurrence. Organizations should also partner with a company that can make tracking compliance easy.
Many organizations may struggle to find time to devote to GHS compliance or to understand if the regulation applies to them, but it’s essential that they create a plan to get all workers trained and utilize outside experts when they feel overwhelmed by OSHA’s requirements.