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TRAINER’S GUIDE G S HazCom UNDERSTANDING Hazard Communication and the Global Harmonization System

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Page 1: HazCom-GHS (TG) Front&Back Cover-UPDATE-2final GHS 4/14/14 ...€¦ · Global Harmonization System HazCom-GHS (TG) Front&Back Cover-UPDATE-2final_GHS 4/14/14 9:47 AM Page 1 . 5721

TRAINER’S GUIDE

GSHazComUNDERSTANDING

Hazard Communication and the Global Harmonization System

HazCom-GHS (TG) Front&Back Cover-UPDATE-2final_GHS 4/14/14 9:47 AM Page 1

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5721 Arapahoe Ave. A-2 • Boulder, CO 80303P.O. Box 19094 • Boulder, CO 80308-2094

(888) 925-6554 • (303) 413-0847 • fax (303) [email protected] • www.excalvisual.com

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Hazard Communication and the Global Harmonization System

GS

TRAINER’S GUIDE

HazComUNDERSTANDING

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All material in this program is the exclusive property of the copyright holder.Copying, transmitting or reproducing in any form or by any means without priorwritten permission from the copyright holder is prohibited (Title 17, U.S. CodeSections 501 and 506).

©2013/2014

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TABLE OF CONTENTSINTRODUCTION TO THE HAZCOM STANDARD � 1

WHEN EMPLOYEE TRAINING MUST BE DONE � 2

EMPLOYEES TO INCLUDE IN HAZCOM TRAINING � 3

IDENTIFYING A HAZARDOUS CHEMICAL � 3

HAZCOM “NECESSARY INFORMATION” � 4

HAZCOM “REQUIRED TRAINING” � 5

USING THE TRANSITION VERSION FOR TRAINING � 6

USING THE FINAL VERSION FOR TRAINING � 8

OTHER REQUIRED TRAINING � 10

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INTRODUCTION TO THE HAZCOM STANDARD

The Occupational Safety and Health Administration (OSHA) issued the Hazard Communication (HazCom) Standard (29 CFR 1910.1200) in 1994. The Standard was amended in 2012 to make it consistent withthe Global Harmonization Standard (GHS) of the United Nations. TheHazCom Standard requires that all hazmat employers provide “effective(emphasis added) information and training” for their employees whocould be exposed to any hazardous chemical known to be present in theirworkplace. Exposure could arise from “normal conditions of use or in a foreseeable emergency.”

The employer may train employees on the specific hazardous chemicalspresent in their work areas or on classes of hazardous chemicals. Thistraining kit, Understanding GHS HazCom, is designed to train workers on classes of hazardous chemicals. This kit includes two training videos:the “transition version,” for the period when GHS is being phased-in, and the “final version,” to be used after the transition is complete.

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WHEN EMPLOYEE TRAINING MUST BE DONE

Employers must provide employees with effective information and trainingon the hazardous chemicals in their work areas at the time of their initialassignment. New hires whose work will involve hazardous chemicals andcurrent employees transferred into jobs involving hazardous chemicalsmust be trained before starting work. Current employees who have alreadybeen trained in compliance with the HazCom Standard as it relates to thehazardous chemicals in their work areas do not need further training.

The 2012 GHS amendments state (Federal Register, Vol. 77, No. 58, pg 17638) that employers should conduct complete refresher trainingclose “to the effective date when all products have been converted toGHS-compliant SDSs and labels.” This would be in late 2015/early 2016. Many employers also choose to conduct regular refresher training, often annually.

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EMPLOYEES TO INCLUDE IN HAZCOM TRAINING

Any employee who works with or around any hazardous chemical eitherregularly or occasionally requires HazCom training. Typically thisincludes some or all:

� Cleaning staff� Maintenance employees� Material handlers� Production workers� Processing workers� Receiving personnel� Stores and warehouse workers� Unit operators

Normally, employees who only pass through areas where hazardouschemicals are stored or used do not receive HazCom training thoughmany employers choose to train virtually all employees.

IDENTIFYING A HAZARDOUS CHEMICAL

Under the GHS amendments, “hazardous chemicals” are defined as “anychemical which is classified as a physical hazard or a health hazard, asimple asphyxiant, combustible dust, pyrophoric gas, or a hazard not otherwise classified.” If the manufacturer, importer, or distributor of asubstance has issued a Safety Data Sheet (SDS) on a substance or mixtureof substances, it is probably a hazardous chemical. Safety Data Sheetswere formerly called Material Safety Data Sheets (MSDS).

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Consult the SDS (or MSDS) on each chemical or material used at thefacility. It will describe any hazards. If no SDS (or MSDS) can be located, before assuming any chemical is not a hazardous chemical, the manufacturing, importer and distributor should be contacted.

However, the substances listed below are specifically exempted from theHazCom Standard even if they meet the definition of a hazardous chemical:

� Articles� Biological hazards� CERCLA hazardous substances (being removed or remediated)� Consumer products (with some exceptions)� Cosmetics� Drugs� Food or alcoholic beverages� Hazardous (RCRA) waste� Nuisance particulates� Radiation� Tobacco or tobacco products� Wood or wood products

Any of these products used in the workplace (with some exceptions) do not need to be covered in the HazCom Program—even if an SDS (or MSDS) has been issued.

HAZCOM “NECESSARY INFORMATION”

Necessary Employee Information:1. The requirement for HazCom training2. Any operations in the employee’s work area where hazardous

chemicals are present3. The location and availability of the facility’s written HazCom Plan

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All affected employees must be told that their employer is required toinform and train them about hazardous chemicals to which they could be exposed at work. This includes sharing that the facility has a HazComPlan that is available for examination. Employees should be told how to request to examine the Plan.

The specific operations at their facility (or in their work areas) where hazardous chemicals are present should be identified. The location of theHazCom Plan, the complete list of hazardous chemicals and the SafetyData Sheets for all hazardous chemicals to which they could be exposedshould also be provided.

HAZCOM “REQUIRED TRAINING”Required Employee Training:

1. Methods and observations that may be used to detect the presence or release of hazardous chemicals

2. The hazards of the chemicals in the work area3. Measures employees can take to protect themselves4. Details of the facility hazard communication program

The Understanding GHS HazCom training kit is designed to help regulatedfacilities provide effective training to employees on hazard communicationand to comply with the revised (2012) HazCom Standard. Two HazComtraining videos are included in this training kit.

The Transition Version

Up to December 1, 2015, both pre-GHS and GHS hazard communicationmethods will be in use by chemical manufacturers, importers and distributors. Suppliers are transitioning from the old to the new methods.During the transition period hazmat employees who have not already beenadequately trained on the HazCom Standard can be trained on both hazard

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communication methods. This training requirement will apply primarily to new hire employees and those who have been transfered from jobs that do not involve hazardous chemicals to jobs that do.

The Final Version

After December 1, 2015, employees who have not been adequately trainedon the HazCom Standard must receive training. This training requirementwill apply primarily to new hire employees and those who have beentransferred from jobs that do not involve hazardous chemicals to jobs that do. This training will reflect only the GHS hazard communicationmethods. Non-GHS communication will no longer be allowed by chemicalmanufacturers, importers and distributors after this date. The Final Versionof the kit is designed for this training.

Both program versions can also be used for refresher training during the appropriate time periods.

USING THE TRANSITION VERSIONFOR TRAINING

Prior to the training session:

STEP 1: Identify all affected employees (those who could potentially beexposed to any hazardous chemical either during normal use or during aforeseeable emergency) and those that need training (or refresher training)on the HazCom Standard. This training will cover the pre- and post-GHS(unchanged and changed) requirements. Schedule a training session(s) for these employees.

STEP 2: The trainer should complete the SiteCast® “HazardCommunication – Facility Specific Training” program, created withPowerPoint® presentation software. The SiteCast® template included

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in the kit will guide the trainer on entering site-specific information. This will include the locations where hazardous chemicals are used at the facility. It will also include monitoring conducted at the facility (ifany). The trainer may complete a single SiteCast® presentation for theentire facility or, if different work areas involve different hazardous chemicals, one for each operation, work area or type of work area.

In the training session:

STEP 3: Provide employees with the “necessary information” and the“required training” (See pages 4 & 5 of this Trainer’s Guide). Present theedited SiteCast® “Hazard Communication – Facility Specific Training”program. The trainer must narrate the SiteCast® presentation and describethe content.

STEP 4: Show affected employees the 23 minute video contained in the kit Understanding GHS HazCom (Transition Version).

STEP 5: Answer any questions from employees.

STEP 6: Administer the Transition Version Quiz. Quizzes can be printedfrom the training disc or copied as needed from the sheets included in thekit. Make sure each employee fills out the name and date on the Quiz sheet.

STEP 7: Have employees self-grade/correct their Quizzes.

STEP 8: Collect and review corrected Quizzes. Any employees whosescores are inadequate may require additional training. NOTE: The trainermay establish a passing score that he/she judges to be “effective training.”

STEP 9: Trainers who do not wish to quiz their employees may haveemployees sign the “Acknowledgment of Training” form included in the kit to document training. File the signed Acknowledgment of Training formand/or Quizzes with the HazCom Plan or in a separate HazCom Trainingfile. Also make and file records of any additional or remedial training performed.

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USING THE FINAL VERSION FOR TRAINING

After December 1, 2015, affected employees who have already beentrained will not need to be re-trained unless a new chemical hazard isintroduced into their workplace(s). However, new hire employees andthose assigned from jobs that do not involve hazardous chemicals to jobsthat do, will need to be trained.

Prior to the training session:

STEP 1: Identify all affected employees that have not received priorHazCom training. Schedule a training session(s) for these employees.

STEP 2: The trainer should complete the SiteCast® “HazardCommunication – Facility Specific Training” program, created withPowerPoint® presentation software. The SiteCast® template included inthe kit will guide the trainer on entering site-specific information. Thiswill include the locations where hazardous chemicals are used at the facility. It will also include monitoring conducted at the facility (if any).The trainer may complete a single SiteCast® presentation for the entirefacility or, if different work areas involve different hazardous chemicals,one for each work area or type of work area.

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In the training session:

STEP 3: Provide employees with the “necessary information” and the“required training” (See pages 4 & 5 of this Trainer’s Guide). Use theedited SiteCast® “Hazard Communication – Facility Specific Training”program. The trainer must narrate the SiteCast® presentation and describethe content.

STEP 4: Show affected employees the 20 minute video contained in the kit Understanding GHS HazCom (Final Version).

STEP 5: Answer any questions from employees.

STEP 6: Administer the Final Version Quiz. Quizzes can be printed fromthe training disc or copied as needed from the sheets included in the kit.Make sure each employee fills out the name and date on the Quiz sheet.

STEP 7: Have employees self-grade/correct their Quizzes.

STEP 8: Collect and review corrected Quizzes. Any employees whosescores are inadequate may require additional training. NOTE: The trainermay establish a passing score that he/she judges to be “effective training.”

STEP 9: Trainers who do not wish to quiz their employees may haveemployees sign the “Acknowledgment of Training” form included in the kit to document training. File the signed Acknowledgment of Training formand/or Quizzes with the HazCom Plan or in a separate HazCom Trainingfile. Also make and file records of any additional or remedial training performed.

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OTHER REQUIRED TRAININGWhen any new hazard is introduced into a workplace after initial training,updated training will be required and should be conducted promptly.Included in the kit is a SiteCast® “Hazard Communication – New Hazards”program, created with PowerPoint® presentation software. It allows thetrainer to quickly create a new hazard training presentation.

Prior to the final implementation date for GHS (June 1, 2016) most regulated facilities should consider re-training all affected employees.Employees should be made aware that GHS is now fully implemented and they should no longer see MSDSs or non-GHS shipping labels.

Small changes like new suppliers, product name changes, and label re-design may not trigger mandatory re-training but can lead to employeeconfusion. Many employers prefer to refresh their HazCom training periodically, even in the absence of hazardous chemical changes.

Other OSHA training related to HazCom may be required. For example,use of certain personal protective equipment (PPE) can trigger specialtraining.

This training kit includes a poster (GHS HazCom Shipping Labels Dissected)that can be placed wherever hazardous chemicals are used, stored or handled.It will remind employees how to interpret these labels and will visuallyexplain and refresh how GHS labels communicate hazard information.Additional posters may be ordered from Excal Visual, if needed.

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training aids include:DOT (General Awareness/Familiarization)

�Environmental Management Systems

�Environmental Awareness

�First Responder Awareness Level (HAZWOPER)

�Fuel Economy

�GHS Hazard Communication (HazCom)

�Hazardous Materials Spill Response

�Hazardous Waste (RCRA) for LQGs

�Hazardous Waste (RCRA) for SQGs

�Hazardous Waste (California)

�Hazardous Waste for Laboratories & Research Facilities

�Pandemic Workplace Strategies

�Spill Prevention Control and Countermeasure (SPCC)

�SPCC/APSA for California

�SPCC for Electric Utilities

�Stormwater Pollution Prevention: Construction Sites

�Stormwater Pollution Prevention: General BMPs

�Stormwater Pollution Prevention: IDDE

�Stormwater Pollution Prevention: Industrial Facilities

�Stormwater Pollution Prevention: MS4s–Municipal Facilities

�Universal Waste

5721 Arapahoe Ave. A-2 • Boulder, CO 80303(888) 925-6554 • Fax (303) 413-0683

www.excalvisual.comVisit our website to request a free trial or to find the latest releases

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