Components of a Well-Managed Training Program

Rachel Krubsack, Editor - EHS

October 11, 2023

Person reading chemical labels

Determine who needs to be trained and when

OSHA’s Hazard Communication (HazCom) standard requires that you train employees who are exposed to hazardous chemicals in their work area before they’re initially assigned to those jobs. An “employee” is defined under HazCom as any worker who may be exposed to hazardous chemicals under normal operating conditions or in foreseeable emergencies.

Although the standard doesn’t require it, it’s a best practice to provide annual HazCom training. Refresher training must be conducted whenever a new chemical hazard, such as flammability, is introduced into the workplace. Additionally, if employees aren’t putting into practice what they’ve learned, it’s time to revisit training to ensure their safety. It may not be necessary to repeat your entire HazCom training program, but to address the specific issue employees are struggling with, like how to use the information found in Safety Data Sheets (SDSs) or when to wear personal protective equipment (PPE).

What must be covered in training?

HazCom training must address:

  • The general requirements of the HazCom standard (1910.1200);
  • Where hazardous chemicals are located in employees’ work areas, the hazards of those chemicals, and how employees can protect themselves;
  • Explanations of the employer’s written HazCom program, labels on shipped containers and in-house labels (if different), and SDSs, and how workers can obtain and use this information; and
  • How to detect hazardous chemicals in the work area (such as through monitoring devices, or visual appearance or odor of hazardous chemicals when being released).

Training can be done by individual chemical, or by categories of hazards, such as flammability. If there are only a few chemicals in the workplace, you may choose to discuss each one individually.

Maintain training records

It’s a best practice to keep a record of employee training, although HazCom doesn’t require it. Documentation helps ensure your training program stays organized, and it also supplies an answer to one of the first questions an OSHA compliance officer will ask: “Did the employee(s) receive adequate training to do the job?” A common industry practice is to take attendance of all employees who attended the training session along with a summary of what material was presented.

J. J. Keller's Chemical Management Service provides EHS professionals a complete solution to help effectively manage a HazCom safety program including managing Safety Data Sheets, reviewing your policies and creating custom HazCom training.