Since there are only a few chemicals in the workplace, discuss each one individually. Employees must also have access to the substance-specific information on the labels and SDSs. Note: It is not sufficient to just read material to your employees or simply hand them material to read. You must create a climate in which employees feel free to ask questions to help you to ensure the information is understood, reducing the risk of an accident. Remember that the underlying purpose of the HCS is to reduce the incidence of chemical- source illnesses and injuries through education about the chemicals and protective measures. With a successful program you and your employees will better understand the chemical hazards in the workplace. The procedures you establish will, reduce the risks posed to employees exposed from the chemical hazards. Since you will be doing the training you need to understand the material and be prepared to motivate your employees to learn. This is not always an easy task, but the benefits are worth the effort. More training information can be found in OSHA Publication No. 2254 containing voluntary training guidelines prepared by OSHA’s Training Institute. OSHA does not expect that every worker will be able to recite all of the information about each chemical in the workplace. In general, the most important goals of training under the HCS are to ensure that employees are aware that they are exposed to hazardous chemicals, that they know how to read and use labels and Safety Data Sheets, and that, as a consequence of learning this information, they are following the appropriate protective measures that you establish. If visited by OSHA, the compliance officers will talk to your employees to determine if they have received training, if they know they are exposed to hazardous chemicals, and if they know where to obtain substance-specific information on labels and SDSs. Although the rule does not require you to maintain records of employee training, it is recommended you do so. Regardless of the method, you are ultimately responsible for ensuring your employees are adequately trained. If the compliance officer finds the training is deficient, you will be cited for the deficiency regardless of who actually provided the training on your behalf, and monetary penalties may be assessed. Train employees to take extra caution in non-routine situations where they could be exposed to a hazardous chemical. This could happen when they do an occasional task such as cleaning an oven with a special product during a move-out clean. Other Requirements under the HCS In addition to the specific items already covered, OSHA compliance officers will also ask the following questions when assessing the adequacy of the program: Does a list of the hazardous chemicals exist in each work area or at a central location? Have you outlined the methods you will use to inform employees of the hazards of non-routine tasks outlined?
3.4.4
MOLLY MAID Safety Manual
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