Staying on Top of Hazmat Training Requirements

The key standard for working with hazardous chemicals is 29 CFR 1910.1200, the revised Hazard Communication Standard, which has been aligned with the Globally Harmonized System of Classification and Labeling of Chemicals.

• By Fred Elliott
• Mar 01, 2017

OSHA's online "Working With Hazardous Materials" page¹ is a useful guide to this topic, ranging from hazards encountered by forklift operators who move hazardous materials to workers handling hazardous chemicals in their workplaces and thus in need of hazard communication training and materials.

The guide covers U.S. Department of Transportation hazmat regulations, which are subdivided by function into four basic areas:

• Procedures and/or Policies (49 CFR Parts 101, 106, and 107)
• Material Designations (49 CFR Part 172)
• Packaging Requirements (49 CFR Parts 173, 178, 179, and 180)
• Operational Rules (49 CFR Parts 171, 173, 174, 175, 176, and 177)

It also covers the OSHA HAZWOPER (Hazardous waste operations and emergency response) Standard, 29 CFR 1910.120, which applies to emergency response personnel who respond to a hazmat incident. If the operator of the vehicle moving hazardous materials becomes actively involved in an emergency response, then he or she is considered an emergency responder and is covered by 29 CFR 1910.120(q), it notes.

Other OSHA standards relevant to the topic of safe work with hazardous materials include 29 CFR 1910.134, respiratory protection; 29 CFR 1910.178, powered industrial trucks—it contains sections on storing and handling liquid fuels and storage and handling of liquid petroleum gas—plus, for shipyard employees, 29 CFR 1915 Subpart Z, toxic and hazardous substances; and, for construction employers, 29 CFR 1926 Subpart Z, toxic and hazardous substances.

Penalties for hazmat violations, in the United States and abroad, can be significant. On Jan. 3, 2017, a British engineering company was fined £150,000 (about $188,000 in U.S. dollars) for a July 2014 incident where two of its employees were seriously burned while using caustic soda—sodium hydroxide—granules to clean piping. The chemical reacted with water in the piping system, heating up and ultimately causing a hose to detach. Both workers were sprayed with the solution and suffered burns, with one suffering life-threatening burns, investigators from the Health and Safety Executive found. The company had not adequately assessed the job’s risks, secured suitable equipment, or provided adequate personal protective equipment to those employees, according to HSE, which reported that the company pleaded not guilty to breaching Section 2(1) of the Health and Safety at Work Act 1974 but was found guilty and fined. No costs were awarded because the company was in liquidation at the time of the sentencing.

"If a suitable risk assessment had been undertaken," said HSE inspector Laura Catterall, "it would have identified that the equipment being used was not right for the chemicals or the work being carried out. All companies who work with high-hazard chemicals should learn from this case and ensure that their workers are properly protected."

Training and the HazCom Standard’s Mandates
"EPA, OSHA, and DOT each have separate training rules, but there is often overlap among the various requirements. OSHA’s goal is to reduce worker injury and illness. DOT requires all employees who handle or transport hazardous materials to receive general awareness, function-specific, and safety training. EPA training focuses on eliminating the release of pollutants and wastes, both on and off site," according to OSHA’s page on moving hazardous materials with powered industrial trucks.

The key standard² for working with hazardous chemicals is 29 CFR 1910.1200, the revised Hazard Communication Standard (HCS), which has been aligned with the Globally Harmonized System of Classification and Labeling of Chemicals, or GHS.

The HCS is intended to address comprehensively the issue of classifying the potential hazards of chemicals and communicating information on the hazards and appropriate protective measures to workers. It spells out how to maintain a written hazard communication program, properly label containers of chemicals in the workplace and chemical containers to be shipped to other workplaces, preparing and distributing Safety Data Sheets to employees and downstream employers, and the development and implementation of employee training programs.

Listed in 1910.1200(h) are the requirements for employee training. It says that "Employers shall provide employees with effective information and training on hazardous chemicals in their work area at the time of their initial assignment, and whenever a new chemical hazard the employees have not previously been trained about is introduced into their work area. Information and training may be designed to cover categories of hazards (e.g., flammability, carcinogenicity) or specific chemicals. Chemical-specific information must always be available through labels and safety data sheets."

This section also says employees are to be informed of the training requirements, about any operations in their work area where hazardous chemicals are present, and about the location(s) and availability of the written HazCom program, including the required lists of hazardous chemicals and the required Safety Data Sheets.

At minimum, employees' training must include these matters:

1910.1200(h)(3)(i)
Methods and observations that may be used to detect the presence or release of a hazardous chemical in the work area (such as monitoring conducted by the employer, continuous monitoring devices, visual appearance or odor of hazardous chemicals when being released, etc.).

1910.1200(h)(3)(ii)
The physical, health, simple asphyxiation, combustible dust, and pyrophoric gas hazards, as well as hazards not otherwise classified, of the chemicals in the work area.

1910.1200(h)(3)(iii)
Measures employees can take to protect themselves from these hazards, including specific procedures the employer has implemented to protect employees from exposure to hazardous chemicals, such as appropriate work practices, emergency procedures, and PPE to be used.

1910.1200(h)(3)(iv)
The details of the hazard communication program developed by the employer, including an explanation of the labels received on shipped containers and the workplace labeling system used by the employer, and the safety data sheet, including the order of information and how employees can obtain and use the appropriate hazard information.

These are OSHA's major training regulations related to the shipping of hazardous materials:

• 1910.38, Emergency action plans. It covers training of employees to assist in a safe and orderly evacuation of other employees.
• 1910.178, Powered industrial trucks. It includes training requirements for the use of forklifts in hazardous locations.
• 1910.120, Hazardous waste operations and emergency response. It lists requirements for different worker populations and determining whether a hazmat release is covered by the standard.
• 1910.134, Respiratory protection. Its training requirements cover respiratory hazards, type of respirators, respirator selection, fitting and maintenance, medical surveillance, and respirator training and administration.
• 1910.145, Specifications for accident prevention signs and tags. It includes training requirements for identifying signs and tags, hazard determination, and precautions to take for personal protection as indicated by signs.
• 1910.157, Portable fire extinguishers
• 1910.165, Employee alarm systems. Its training requirements cover how to explain to employees the preferred means of reporting emergencies.
• 1910.1200, Hazard communication.
• 1910.1201, Retention of DOT markings, placards, and labels.

References
1. Working with Hazardous Materials, https://www.osha.gov/SLTC/poweredindustrialtrucks/hazmat.html
2. https://www.osha.gov/SLTC/hazardoustoxicsubstances/index.html

This article originally appeared in the March 2017 issue of Occupational Health & Safety.