By Mike Moffatt, Ph.D.
Nexreg Compliance, Inc.
Under the U.S.’ GHS-based Hazcom 2012 rule, employers are expected to train “employees on the new label elements and safety data sheet (SDS) format” by December 1, 2013. This training is to be given to all employees that would normally receive any OSHA training. Note there are additional training requirements in Hazcom 2012, but only the “new label elements and safety data sheet format” training requirements are subject to the December 1, 2013 deadline.
OSHA has a helpful document on the minimum requirements for the training elements required by December 1, 2013 available at: https://www.osha.gov/Publications/OSHA3642.pdf. Included are training on the label elements: product identifier, signal word, pictograms, hazard statements, precautionary statements, company contact info. Employers are required to explain how an employee might use the labels in the workplace, general understanding of how the elements work together on a label, how the information on the label is related to the SDS as well as the information located in each of the 16 sections of the SDS.
We have been recommending to our client that they are vigilant in recording the date and method for each employee that was trained. Furthermore, we recommend (though it is not a firm requirement) that any employee receiving training is given a written test on what they have learned, as it is a requirement that training be given in “a language and vocabulary that employees can understand.”