Developing a Training Program for the GHS Changes to OSHA's Hazard Communication Standard

摘要

This paper is intended to provide IPC members with the knowledge and resources needed to help them comply with the employee training requirements of the revised OSHA Hazard Communication Standard. On March 20, 2012, OSHA revised its Hazard Communication Standard to align it with the United Nations' Globally Harmonized System of Classification and Labeling of Chemicals (GHS). GHS has been implemented, or is in the process of implementation, in 67 countries around the world. OSHA's action should facilitate international trade, improve employees' understanding of chemical hazards, and make workplaces safer. However, it requires that employers revise their existing Hazard Communication Programs. An important consequence affecting members of IPC will be the need to train employees on the new hazard labels and Safety Data Sheets (SDS) mandated by GHS. This training must take place by December 1, 2013. Chemical manufacturers and importers must transition to the new label and SDS format by June 1, 2015. An additional 6 months (until December 1, 2015) is allowed for chemical distributors to clear inventories of chemicals labeled in the old format. Once chemical users have received their updated labels and data sheets, they will have an additional 6 months (until June 1, 2016) to update any in-house labeling system they may be using, and to train employees on any new hazards identified on the updated labels or data sheets. Hazard Communication is the standard most frequently cited by OSHA for General Industry, and it affects an estimated 5 million workplaces nationwide. This has resulted in a flood of GHS training programs being aggressively marketed by vendors, as well as new vendors and websites being created dedicated to GHS. This paper will address the following: 1. Background on changes to the Hazard Communication Standard. 2. Required topics for training new employees. 3. Required topics for employees already trained under the old standard. 4. Deciding among options for developing and delivering training. 5. Comparing training content developed by vendors. 6. Resources for developing in-house training programs.