Taking the Hazard Out of Hazardous Chemicals
OSHA defines a 16-section format for all safety data sheets to adhere to.
- By Holly Mockus
- Sep 01, 2021
Chemicals are used in most workplaces, ranging from household cleaning products to extremely flammable gasses and toxic metals. It Is ironic that the same chemicals that help make safe products and keep work environments clean and healthy can also be dangerous, even deadly, if used incorrectly.
Employers have clear responsibilities regarding chemical use: appropriately labeling containers, keeping safety data sheets (SDS) updated and available and providing relatable employee training. These are not only ethical responsibilities, but they are also legal requirements, as specified in OSHA’s Hazard Communication Standard 1910.1200(e).
The 3-1-1 on SDS
Proper labels and SDS are critical. OSHA defines a 16-section format for all SDS to adhere to. The uniformity helps users find relevant information quickly–especially if they are familiar with SDS. Some safety managers find the format easy to follow, others may need some assistance when reviewing an SDS.
Four of the 16 sections are non-mandatory. If a chemical manufacturer did not include these sections in its product SDS, but that chemical is in use at your facility, it could be a good idea to insert this information. Information on proper disposal, transportation and ecological impact should be included to ensure employees know how to proceed during these situations.
Companies that have all of their SDS on file may still benefit from a third-party review to find gaps in existing materials and work processes. Vet any consultant’s credentials and nothing beats a real conversation to help find a good fit for your needs.
SDS is Step One: (Over) Communication Must Follow
We all know the riddle: If a tree falls in the woods with no one around, does it make a sound? Less of a riddle is this question: Does a perfectly written SDS make a safer workplace all on its own? “No” is the clear answer.
Your workplace is only as safe as your people are trained. A perfect volume of SDS, accurate labels and fail proof processes on paper are of no use if the workers are not trained to utilize them properly.
Successful training requires great content, engaging delivery and seamless documentation to keep track of any employees who missed training or need additional assistance. So, let’s take a closer look at these three elements.
Chemical Safety: What Employees Need to Know
Often, the hardest part about adult learning is convincing the adult they need to learn something. This is natural, because many adults think of school as a thing in the past. When it comes to chemical safety, most workers will correlate labels on the containers to labels on the household chemicals they use regularly. This can lead to false overconfidence. Confidence without proper knowledge is extremely dangerous.
Chemical safety training should cover these key, high-level concepts at a minimum:
*Chemicals used at work can be more concentrated and pose greater risks than chemicals used at home, which is why they require more detailed information beyond the label.
*Introduce SDS and where they can be found.
*Present the standard sections of every SDS, teaching the uniform format will enable workers to use SDS correctly.
*Emphasize key sections on hazard identification and proper use.
*Demonstrate the nine universal hazard symbols of the Globally Harmonized System of Classification and Labeling of Chemicals (GHS).
*Teach employees how to protect themselves with the right PPE worn properly.
*Provide reasons behind proper handling instructions, for example:
*If mixing with water, add the chemical to the water (instead of adding water to chemical) so a splash would be water instead of chemical.
*Don’t pour chemicals into a container that sits above eye level to avoid splashing in eyes.
*Never mix acids and chlorinated products, which could release deadly fumes.
*Emergency preparedness: ensure employees know where eye wash stations, emergency showers and spill kits are and how to use them.
Developing this training content can seem overwhelming. Adding to the challenge, most safety experts are not trained in curriculum development, and likewise, most training coordinators are not safety experts. Collaboration between these two departments is essential. There are solutions to expedite and streamline the effort.
A number of quality third-party training vendors provide chemical safety training courses. Choose the right vendor by finding the best fit for your particular needs. Here are some things to consider:
*Are the courses locked, or are they customizable to add site-specific elements if needed?
*Do the courses come in the languages you need for your workforce?
*Are the courses compatible with your learning management system (LMS)?
*If you don’t have a LMS, do they come with a basic LMS to properly track and deliver?
*Do you need a one-off course for chemical safety, or is a wider workplace safety library of courses needed?
*Is eLearning, classroom training or a combination more desirable?
Finally, a word for the wise. Any vendor that claims its training course(s) are “OSHA approved,” “OSHA certified,” or otherwise sanctioned by OSHA is being disingenuous. OSHA does not approve or certify training content or training providers.
Keeping Employees Alert and Engaged
The job is not done after the training materials are created. Even the best, most accurate content possible could miss the mark if it does not keep learners engaged and interested. It is important to remember that many workers may see training as a bother. After all, they are adults and, in many cases, have performed work with chemicals in the past and nothing went wrong. Therefore, they might feel training is unnecessary. But the 60,000 workplace deaths per year in the U.S. due to chemical exposure (on top of another 860,000 injuries) is another story.
Story-telling is actually a great method to make training more engaging. Adult learning experts weave narrative stories into training courses, which hold attention better than lists, droning instructions and data alone. Another proven concept involves “microbursts” of learning. This is a fancy way to say you are teaching one or two concepts at a time, with concise instruction. Find ways to repeat these concepts before introducing new concepts. Stitch together a series of these microbursts to round out the instruction.
Even with great course structure, stronger engagement tactics are recommended. A common best practice includes intermittent quizzes throughout a course. Many employers prefer a quiz at the end, and this is fine. But quizzes during a training segment helps verify understanding and requires a learner to pay attention. A long stretch without requiring interaction or input from the learner invites distraction.
Another tactic, specific to eLearning courses, is known as “auto pause” or “focus lock.” This feature automatically pauses an eLearning course if the student navigates to another browser window or other app on the computer. This prevents a learner from playing a course in the background while doing other work or from taking two courses simultaneously. The eLearning only resumes once the learner navigates back to the browser window with the course, ensuring multi-tasking isn’t possible to keep focus on the instruction.
Documenting Chemical Safety Training
When it comes to chemical safety documentation, keeping accurate SDS is top of mind for safety directors. Yet current chemical safety employee training records are just as important to comply with OSHA’s Hazard Communication Standard. Again, a strong partnership with HR or learning and development departments is beneficial.
Most companies with more than a couple dozen employees will have an LMS in place. If not, a manual process of sign-in sheets and quiz grading for chemical safety training may be in use. It is tedious but can be done. It will require strict discipline and meticulous filing and classification, especially if ever needed for an audit.
The problem with manual record-keeping—aside from inefficiency and opportunity for errors—is it makes it near impossible to be proactive with training. An LMS makes it easy to instantly see which employees have passed chemical safety training and which haven’t, as well as those who are due for refresher training. It is no surprise a recent survey representing more than 4,000 facilities found organizations using an LMS are:
*49 percent more likely to be able to verify any individual employee understood their safety training.
*30 percent more likely to provide refreshers and reinforcement for safety training.
*26 percent more likely to provide documented safety training to temporary and contract workers.
All of the above can have a huge, positive impact on an organization’s chemical safety program. With hazards and injuries ranging from instant chemical burns and explosions to slow-to-surface skin disease and respiratory illnesses, the need for training beyond a one-and-done approach is necessary for all employees.
This article originally appeared in the September 2021 issue of Occupational Health & Safety.