In accordance with various regulations, many facilities require EHS training for all new employees upon hire and annually thereafter. It is great to have an established and informative training program in place, but do you remember to inform your employees of new hazards introduced into the workplace?
New hazards can be introduced by literally bringing in material with hazards not previously present at the work place, or new hazards can be introduced by making modifications to existing tasks and procedures that create a new hazard. While it would be impossible to cite all of the regulatory requirements for training at your facility, a few basic citations will give you an idea of the importance of providing training as hazards are introduced or modified.
OSHA’s Hazard Communication Standard, 29 CFR 1910.1200, requires employers to provide employees with effective training on the hazardous chemicals present in their work area upon initial assignment and whenever a new chemical hazard is introduced into the work area. OSHA’s Lab Standard, 29 CFR 1910.1450, requires employers to provide the same training prior to initial assignment to a work area where hazardous chemicals are present, as well as prior to assignment to work involving new exposure situations. Both standards require the contents to include methods of detection, the hazards of the chemicals, and the measures that can be implemented to protect exposure, including specific work practices, emergency procedures, and personal protective equipment appropriate for the hazards. As hazards change, the applicable sections of the hazard communication program and chemical hygiene plan need to be updated, and also covered during training sessions.
OSHA’s Bloodborne Pathogen Standard, 29 CFR1910.1030, requires employers to provide additional training when task or procedure changes affect the employee’s occupational exposure.
Training sessions to keep employees informed of hazard modifications throughout the year should be focused on the new hazards and how employees can protect themselves from exposure. And remember to update the annual training sessions as programs evolve.