The viability of a chemical safety program cannot be overrated. Unfortunately, most schools and universities don't emphasize their programs the way they should.
Hazardous communication statutes have been on the books for more than 14 years, but many schools hardly meet the letter of the law, much less the spirit. If you ask most custodial supervisors or managers in schools and colleges what they do for HAZCOM, most would say they have standard programs, either on video or presented live, to educate their employees about the laws pertaining to this important topic.
But like many training programs, the real test is not which training program you have or how well someone teaches it. What's important is how well your employees know the chemicals they are using, if they can find information about those chemicals and, most important, if they truly understand and respect the regulations that govern chemicals.
HAZCOM was not set up to create problems for managers or employees; it was designed to ensure that organizations trained their staffs how to handle dangerous materials and any problems they might encounter.
But what most schools have adopted to be HAZCOM training fulfills the law only in the respect that they have a training program. There seldom is any training beyond what is required; employees tend to view the training as "just enough to get by."
So, what happens when HAZCOM programs truly are tested? In general, they fail miserably.
TRIAL BY FIRE
Supervisors like to think their employees are well-trained; but most have never tested, in a real way, to determine if that training has been effective. They may administer a written test immediately after training, but these tests often are too simple. And what about a month down the road? How much will an employee remember then? Meaningful tests are not written, but administered on the job, often under duress, in real-life circumstances.
Not long ago I was involved in a emergency-services drill near where I live. Students from a local high school simulated victims from an industrial accident and fire. A local firm allowed the county to use its building as the site of the disaster. No one even knew it was going to take place. Once the "victims" were in place, the director of county emergency services called 911 about the accident - and cautioned the dispatcher that it was only a drill.
Soon the fire brigade from the industrial plant arrived with its equipment and did its job. Then the county response teams, paramedics, firefighters, police and others arrived and did their job. The victims were transported to a clinic where its response was tested. Included in the test were the public relations and security aspects of any emergency that might occur.
Students played nosy reporters with cameras and microphones, as well as distraught family members who tried to get into restricted areas and caused all kinds of problems. The drill was set up to test the training of crews in circumstances as close to real as possible.
FIXING MISTAKES During the drill, county officials assessed responses. They tested the real-life knowledge of the response team members by watching their actions and the results of those actions.
The drill was a success in every way. It revealed shortcomings, which the various agencies can now correct. More than that, it gave the emergency crews confidence to handle such situations.
Ask yourself: How would your school or university live up to a simulated drill that tested your HAZCOM program? Could you design such a test to see what would happen? Do you think it is important enough to do it? Would your employees find themselves heroes or know-nothings?
But the biggest question is this:
How ready are you to find out the truth about what your employees know and how they would perform?
On its website (www.osha-slc.gov/html/faq-hazcom.html), the U.S. Occupational Health and Safety Administration spells out the guidelines for training employees about HAZCOM:
- Employees are to be trained at the time they are assigned to work with a hazardous chemical. The intent is to have information prior to exposure to prevent the occurrence of adverse health effects. This purpose cannot be met if training is delayed until a later date.
- The training provisions of the Hazard Communication Standard are not satisfied solely by giving employees the data sheets to read. An employer's training program is to be a forum for explaining to employees not only the hazards of the chemicals in their work area, but also how to use the information generated in the hazard communication program. This can be accomplished in many ways (audiovisuals, classroom instruction, interactive video), and should include an opportunity for employees to ask questions to ensure that they understand the information presented to them.
- Training need not be conducted on each specific chemical found in the workplace, but may be conducted by categories of hazard (for instance, carcinogens, sensitizers, acutely toxic agents) that are or may be encountered by an employee during the course of his duties.
- Furthermore, the training must be comprehensible. If the employees receive job instructions in a language other than English, then the training and information to be conveyed under the Hazard Communication Standard will also need to be conducted in a foreign language.
Additional training is to be done whenever a new physical or health hazard is introduced into the work area, not a new chemical. For example, if a new solvent is brought into the workplace, and it has hazards similar to existing chemicals for which training has already been conducted, then no new training is required. As with initial training, and in keeping with the intent of the standard, the employer must make employees specifically aware which hazard category the solvent falls within. The substance-specific data sheet must still be available, and the product must be properly labeled. If the newly introduced solvent is a suspect carcinogen, and there has never been a carcinogenic hazard in the workplace before, then new training for carcinogenic hazards must be conducted for employees in those work areas where employees will be exposed.