What is "Training"?

Companies everywhere these days are being cited by OSHA and sued in product liability or related civil lawsuits for not "training" their employees in the potential hazards and precautions to take in their jobs. Similarly, the overwhelming number of product liability suits contain a failure to warn or instruct users properly about safe operating procedures or potential product condition hazards. Why do these safety basics remain in contention?

Concerning chemicals in the work place, today OSHA inspectors routinely ask employees in private interviews:

1) What job tasks do you do?

2) What are the hazards in doing these tasks that you might have been exposed to?

3) What's in that can of [paint] [solvent] [degreaser]?

4) What in there can hurt you?

5) What training have you had about the hazards of that material?

6) What training have you had on how to prevent getting hurt when handling it?

Some employees (and employers) seem to misunderstand what OSHA is looking for. The vague term "training" seems to be a real stumbling block to clear communication. Employees who know perfectly well how to handle safely the chemicals at their worksite, seem to mis-identify "training" to mean only formal classroom-type classes.Yet most MSDS training, in fact, occurs in initial on-the-job orientation and tool box crew safety meetings. Perhaps that is why employers who use classroom type sessions and videotapes geared to specific chemicals seem to fare much better in OSHA hazard communication standard inspections.

Then there is the matter of documentation. OSHA inspectors are beginning to reject one page "generalities" documentation of "MSDS training." Instead, they want to see training documentation of named chemicals, which seems to stretch the bounds of feasibility since HCC standards do not call for formal Chemistry 101 mini-courses. So what have OSHA State or Federal inspectors indicated they want to hear when they investigate whether employees have been trained adequately? Here's what two inspectors recently told us they want to hear when interviewing employees who work with potential skin-burn chemicals:

1) That the material (chemical) in here can burn me if it touches my skin or eyes;

2) That I have to wear impermeable or special gloves and long-sleeve clothing to protect myself;

3) That leather gloves are not adequate to protect me;

4) That I must wear eye goggles and a dust mask while working in the area;

5) That I know to run over to where the eye-wash shower is and pull the chain to wash out my eyes if any of that material gets in my eyes;

6) That I report any injury or hazard I notice in that area; and

7) That I know where to go to see the [MSDS] safety data sheets on any chemical I work with if I have any questions.

Normally, OSHA does not require employees to name every chemical in the department or plant. Nor do they require employees to diagram its chemical formula or be able to identify it as a "dermal irritant."

In short, "training" far beyond just telling employees where the MSDS book is located will be required, but practicality and reasonableness can meet the compliance duty where employees have learned sufficient skills and information about each chemical or hazard in their work areas. Employees also should be informed that their safety meeting sessions accomplishing this practical approach is their hazard "training."

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