Employers may conduct the training in-house or may contract with someone knowledgeable on the revised OSHA hazard communication standard to conduct the training. The employer must provide training in a manner that is understandable by each employee, which means the employer must consider and accommodate limitations such as language, vocabulary, and literacy. Employers are still required to do annual training on hazard communication (HAZCOM) in addition to these new requirements.
Employers must train their employees on the new label elements and the SDS format. This training is necessary to protect themselves from chemical hazards in the workplace. It is critical that employees understand the new label and SDS formats. Training is also required at the time an employee is assigned to work with any hazardous chemical and whenever a new hazard is introduced into the employees work area.
The list below contains the minimum required topics the training.
Training on label elements including:
- Product identifier
- Signal word(s)
- Hazard statement(s)
- Precautionary statement(s)
- How an employee might use the labels in the workplace
- General understanding of how the elements work together on a label
- Where the employee can get all the information on the hazards of the chemical(s)
Training on the format of the SDS
- How to obtain and use the hazard information on an SDS
- Differences between MSDSs and SDSs and how to utilize the MSDS
The employer must provide annual training and maintain records of the training that include:
- Identification of those trained
- Date of the training
- Brief description (e.g., symptoms of CO poisoning, H2SO4 emergency procedures, etc.)
The training records must be maintained for the period of employment + 5 years and must identify the following:
- Identity of the employee trained
- Date(s) of training
- Brief description of the training