Hazard Communication Requirements HR Training Issues

No man is an island.  Either is the environmental health and safety department which typically controls the MSDS binders.  Part of the mandate for MSDSs in the United States is OSHA’s (in)famous hazard communication regulations.  At a basic level the requirements stipulate that all staff must be made aware of any hazardous materials that may come into contact with.  Not only must they be aware of them, but they need to be informed as to the related safety risks that they may be subjected too.

This mandate is usually achieved by making the data sheets available to anyone that wants to access them.  However, many organizations looking to ensure accountablity to the standard will work with the human resources department to implement training on what the MSDSs mean.

Common training topics would include:

  • Where the documents are located
  • Explanation of the HMIS/NFPA hazard codes
  • Explanation of the personal protective equipment (PPE) requirements
  • Explanation on how to find emergency contact numbers

This sounds pretty easy at first glance.  However as always the devil is in the details.  For instance if you wanted to teach a new hire how to find the HMIS PPE data in a MSDS, how would you do it?  Most documents are in black and white so you usually are not looking for a color coded rectangle (unless you perhaps had a system like ours) and many times the information is just text based.  Beyond that difference though there is very little uniformity between documents as to the location.  Some would put it on the front page, some on the last page.  Some would place it in the middle somewhere.

The easiest way to make sure staff has the information they need is to standardize the way in which the information is found and displayed.  If the system is consistent it makes training requirements that much easier.

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