Tell Me All About Hazard Communication Training

Environment

Tell Me All About Hazard Communication Training

This article, the seventh blog of our EHS and compliance training deep-dive blog series, discusses hazard communication training.

The federal Hazard Communication Standard (HCS) is itself pretty standard across the board. Most operations managers are aware of this safety regulation, but few fully realize how important compliance is. The Occupational Safety and Health Administration (OSHA) is responsible for HCS enforcement and updates—and the agency takes it very seriously.

Failure to comply means citation, fines, and dangerous conditions for facilities staff. Fines can amount to $16,131 per violation, which shows how seriously OSHA takes worker protections and wellbeing. As such, it’s crucial to understand HCS and how to fully comply.

Common Chemical Hazards

When improperly used or handled, even the most commonplace chemicals can cause harm. Any time a chemical leaves its bottle or container, there is a risk of a worker being injured. This can be in the form of:

Splashing, which damages skin on contact and causes gastrointestinal distress if ingested
Vapors, which can cause sickness if inhaled
Spills, which result in chemical skin burns or other hazardous situations if these chemicals interact with other chemicals

Chemicals and other hazardous materials are so dangerous that their containers must display all relevant hazard information. This includes many commonly and regularly used lab chemicals. The HCS details a few general worker risks, including:

Flammability: When the chemical can be easily ignited, burns intensely, or displays a rapid rate of flame spread when ignited
Corrosivity: When a chemical can cause visible destruction or irreversible changes to living tissue
Toxicity: When chemicals cause adverse effects when they come into contact with skin, are inhaled, or are ingested

HCS: The Right to Know Law

OSHA’s HCS, also known as the “Right to Know” law, asserts that all employees are entitled to full awareness of ALL workplace hazards. These include the details of relevant workplace chemicals and all necessary hazard information. This takes the form of:

Labels on hazardous materials and chemical containers
Chemical safety data sheets (SDSs)
Training in hazardous materials and procedures
And more

Without these elements in place, organizations risk safety and compliance violations—especially when it comes the HCS-listed chemicals. The HCS is tied closely to the Globally Harmonized System of Classification and Labelling of Chemicals (GHS), consistent criteria for chemical hazard classification that attempts to standardize distillation of hazard information in a straightforward and clear way.

The GHS, enacted by the United Nations (UN) at the turn of the 21^st century, standardized the chemical warning label system at a worldwide scale. OSHA adopted it in 2012, and most UN member countries follow this standard.

Most people recognize the GHS as the series of diamond-shaped pictograms on chemical containers that display hazard data via an image and number. This labeling system allows any stakeholder to immediately understand what chemicals they are dealing with—and enables a fast and informed response to emergency situations.

No Training = Compliance and Safety Disaster

Training is the key to compliance with the Right to Know law, as it ensures people know how to communicate key hazard information—and how to interpret the many ways that hazard information is presented to them.

Training should include:

Worker rights under the HCS
All information access points for relevant chemical hazard information. Each company has their own different databases containing records of used and stored chemicals, and different ways of accessing such information
How to use their organization’s hazard communication program

HCS training only needs to cover safety during routine operations—it does not need to cover emergency response. There are a nearly infinite number of potential harmful scenarios that chemical accidents, mishandling, or just bad luck could cause—any chemical event can mushroom to impact everyone in a facility or worksite.

As such, every last person that works in a facility that uses, manages, or stores hazardous chemicals needs HCS training. Even those in the C-suite, who rarely if ever directly interact with chemicals, need to be fully aware of this communication system—and thus, of any relevant chemical hazard. At the least, every employee should be able to read a hazard label—just in case. This also applies to any onsite contractors.

Annual HCS Training: A Good Best Practice

While training is only officially required at time of hire, annual training is beneficial. This is because HCS regulations can change at any point, and sometimes without warning. Not only that, but a facility may undergo upgrades or buildouts which affect operations—and thus, require training updates. Annual trainings can allow your organization to keep up with these changes.

The UN, for example, published GHS revisions in May 2024—meaning some organizations need to scramble to create new, updated trainings on the fly, with relevant information to support changed compliance requirements. Organizations that regularly update their trainings on an annual basis, however, were able to quickly stay ahead of the curve.

OSHA Regulates HCS and Training Compliance

OSHA sets the rules, and also enforces their compliance—including relevant penalties for noncompliance. While these rules will always be publicized, it will still be your company’s responsibility to comply and respond once the rules go into effect.

All too often, managers are too busy to keep up with OSHA—until the fateful day a regulator shows up and finds an organization noncompliant (usually when it comes signage or labeling errors, which are commonly found). This means a tricky compliance “battlefield,” one that could have been avoided with proactive HCS programs.

Full Compliance Demands Tailored Support

Whether you are looking for support in keeping up with the regulatory changes or need a training program that is tailored to your worksite, Triumvirate Environmental may be the partner for you. Not only do we keep our ear to any relevant HCS OSHA news, but we can also customize trainings and recommendations to your individual system and roll them out successfully.

This can include specifics about: