Training is an integral part of your hazard communication
program. Under the Hazard
Communication Standard, each
employer is required to inform and train employees at the
time of their initial assignment to a work area where hazardous
chemicals are present and whenever a new hazard is introduced
into the work area.
While the outline of topics to
be presented in employee information and training programs
is the same for all employers, the actual information presented
must be based on the specific hazard information conveyed
by labels and SDSs for that particular workplace or work area.
These topics are to be covered
in all information and training programs:
- The provisions of the Hazard
Communication Standard. Any operations in the employees'
work areas where hazardous chemicals are present.
- The location and availability
of the company's written hazard communication program, including
the required list(s) of hazardous chemicals and SDSs required
by the Hazard Communication Standard.
- Methods and observations that
may be used to detect the presence or release of a hazardous
chemical in the work area.
- The physical and health hazards
of the chemicals in the work area.
- The measures employees can
take to protect themselves from these hazards, including
information on work practices, emergency
procedures and personal protective equipment required by
- The details of the employer's
written hazard communication program, including an explanation
of the labeling system used by the employer, SDSs, and how
employees can obtain and use the appropriate hazard information
on the labels and in the SDSs.
up an Employee Training Program
The following sections illustrate how a typical training program
might be designed. Following these guidelines is a non-mandatory
training guide developed by OSHA for conducting an effective
training program. Using these guidelines, together with establishment-specific
label and SDS information, employers can develop effective
employee training programs that achieve the objective of the
Hazard Communication Standard.
Know the Provisions
of the Hazard Communication Standard
- Be familiar with the requirements
of the standard.
- Know your responsibilities
under the law.
- Inform all employees of
the law and their rights under the law.
Employees to be Trained
- Assess actual and potential
employee exposure to hazardous chemicals.
- Determine training needs
based on this exposure during both normal use of hazardous
chemicals and during emergencies.
- Determine appropriate way
in which to train new employees and supervisors.
- Train employees and supervisors
on the specific chemicals in your workplace and their
Know the Hazardous
Chemicals in Your Workplace
Define hazardous chemicals:
Any chemical that is a physical or health hazard.
- "Physical Hazard"
Physical hazard means a chemical that is classified as
posing one of the following hazardous effects: explosive;
flammable (gases, aerosols, liquids, or solids); oxidizer
(liquid, solid or gas); self-reactive; pyrophoric (liquid
or solid); self-heating; organic peroxide; corrosive to
metal; gas under pressure; or in contact with water emits
- "Health Hazard"Health
hazard means a chemical which is classified as posing
one of the following hazardous effects: acute toxicity
(any route of exposure); skin corrosion or irritation;
serious eye damage or eye irritation; respiratory or skin
sensitization; germ cell mutagenicity; carcinogenicity;
reproductive toxicity; specific target organ toxicity
(single or repeated exposure); or aspiration hazard.
Make a List of
the Hazardous Chemicals in Your Workplace
- Your list should include
the names of the chemicals, their hazards, and protective
measures to be taken, and emergency and first-aid procedures.
- Identify the process or
operation where the chemicals are used, and the name and
address of the manufacturer.
- Make sure there is a safety
data sheet (SDS) for each chemical and that the list references
the corresponding SDS for each chemical.
- Make the list readily available
to your employees (or to other employers at your worksite
at their request).
- Make sure employees understand
the information regarding the chemicals listed in the
on How to Use and Interpret SDSs.
- Make sure you have an SDS
for each hazardous chemical product you package, handle,
- Check each SDS you receive
to ensure that it contains all the information required
by the standard.
- Obtain SDSs or information
where necessary (i.e., when SDS is not received from manufacturer,
importer, or supplier, or when SDS is incomplete.
on Labeling Requirements
- Check each container entering
the workplace for appropriate labeling (i.e., identity
of chemicals, hazard warnings; name and address of manufacturer/importer/responsible
- Explain the importance of
reading labels and of following directions for the safe
handling of chemicals.
- Label, tag, or mark containers
into which hazardous chemicals are transferred with the
chemical identity and hazard warnings.
- Hazard warning must convey
specific physical and health hazards of the chemicals.
Explain that words such as "caution", "danger", "harmful
if absorbed by skin", etc. are precautionary statements
and do not identify specific hazards.
- Explain the labeling exemptions
for portable and stationary process containers.
- Label portable containers
when they are not for "immediate use." (Note: Portable
containers require no labels when chemicals are transferred
into them from labeled containers and when the chemicals
will be used immediately by the employee transferring
- In lieu of labels, process
sheets, batch tickets, standard operating procedures,
or other written materials may be used on stationary process
equipment if they contain the same information as a label
and are readily available to employees in the work area
- Cross-reference chemical
identifiers on labels to SDSs and the lists of hazardous
- Be aware of other hazardous
chemicals that may have specific labeling requirements
under other standards (e.g., asbestos, lead, etc.).
Methods of Controlling Workplace Exposures
- Engineering Controls:
changes in machinery, work operations, or plant layout
that reduce or eliminate the hazard (e.g., ventilation
controls, process enclosures/hoods, isolation, etc.).
- Administrative Controls:
good housekeeping procedures, safe work practices, personal
and medical monitoring, shortened shifts or changed work
- Personal Protective
Equipment: safety glasses, goggles, face shields,
earplugs, respirators, gloves, hoods, boots, and full
Review Your Current
Procedures for Handling Chemicals and Compare with Recommended
Practices Identified on SDSs and Labels
Consider Keeping a
Record of Employee/Supervisor Training
Establish a Written
Emergency Action Plan
- Follow-up and evaluate your
training program to make sure employees know how to handle
the chemicals they are using and are applying the training
you have given them.
- Training in procedures such
as emergency controls and phone numbers, evaluation plans,
alarm systems, reporting and shut-down procedures, first-aid,
personal protection, etc.
- How and when to report leaks
Training Record (PDF)
The Occupational Safety and Health Act of 1970 does not
address specifically the responsibility of employers to
provide health and safety information and instruction
to employees, although Section 5(a)(2) does require that
each employer "... shall comply with occupational safety
and health standards promulgated under this Act." However,
more than 100 of the Act's current standards do contain
Therefore, the Occupational
Safety and Health Administration has developed voluntary
training guidelines to assist employers in providing the
safety and health information and instruction needed for
their employees to work at minimal risk to themselves,
to fellow employees, and to the public.
The guidelines are designed
to help employers to (1) determine whether a worksite
problem can be solved by training; (2) determine what
training, if any, is needed; (3) identify goals and objectives
for the training; (4) design learning activities; (5)
conduct training; (6) determine the effectiveness of the
training; and (7) revise the training program based on
feedback from employees, supervisors, and others.
The development of the guidelines
is part of an agency-wide objective to encourage cooperative
voluntary safety and health activities among OSHA, the
business community, and workers. These voluntary programs
include training and education, consultation, voluntary
protection programs, and abatement assistance.
The guidelines provide employers with a model for
designing, conducting, evaluating, and revising training
programs. The training model can be used to develop
programs for a variety of occupational safety and
health hazards identified at the workplace. Additionally,
it can assist employers in their efforts to meet the
training requirements in current or future occupational
safety and health standards.
A training program designed
in accordance with these guidelines can be used to
supplement and enhance the employer's other education
and training activities. The guidelines afford employers
significant flexibility in the selection and content
and training program design. OSHA encourages a personalized
approach to the informational and instructional programs
at individual worksites, thereby enabling employers
to provide the training that is most needed and applicable
to local working conditions.
Assistance with training
programs or the identification of resources for training
is available through such organizations as OSHA full-service
Area Offices, State agencies which have their own
OSHA-approved occupational safety and health programs
for employers, local safety councils, the OSHA Office
of Training and Education, and OSHA-funded New Directions
OSHA does not intend to make the guidelines mandatory.
And they should not be used by employers as a total
or complete guide in training and education matters
which can result in enforcement proceedings before
the Occupational Safety and Health Review Commission.
However, employee training programs are always an
issue in Review Commission cases which involve alleged
violations of training requirements contained in OSHA
The adequacy of employee
training may also become an issue in contested cases
where the affirmative defense of unpreventable employee
misconduct is raised. Under case law well-established
in the Commission and the courts, an employer may
successfully defend against an otherwise valid citation
by demonstrating that all feasible steps were taken
to avoid the occurrence of the hazard, and that actions
of the employee involved in the violation were a departure
from a uniformly and effectively enforced work rule
of which the employee had either actual or constructive
In either type of case,
the adequacy of the training given to employees in
connection with a specific hazard is a factual matter
which can be decided only by considering all the facts
and circumstances surrounding the alleged violation.
The general guidelines presented here are not intended,
and cannot be used, as evidence of the appropriate
level of training in litigation involving either the
training requirements of OSHA standards or affirmative
defenses based upon employer training programs.
OSHA's training guidelines follow a model that consists
- Determining if Training
- Identifying Training Needs
- Identifying Goals and
- Developing Learning Activities
- Conducting the Training
- Evaluating Program Effectiveness
- Improving the Program
The model is designed to
be one that even the owner of a business with very few
employees can use without having to hire a professional
trainer or purchase expensive training materials. Using
this model, employers or supervisors can develop and administer
safety and health training programs that address problems
specific to their own business, fulfill the learning needs
of their own employees, and strengthen the overall safety
and health program of the workplace.
Training is Needed
The first step in the training process is a basic
one: to determine whether a problem can be solved
by training. Whenever employees are not performing
their jobs properly, it is often assumed that training
will bring them up to standard. However, it is possible
that other actions (such as hazard abatement or the
implementation of engineering controls) would enable
employees to perform their jobs properly.
Ideally, safety and health
training should be provided before problems or accidents
occur. This training would cover both general safety
and health rules and work procedures, and would be
repeated if an accident or near-miss incident occurred.
Problems that can be
addressed effectively by training include those that
arise from lack of knowledge of a work process, unfamiliarity
with equipment, or incorrect execution of a task.
Training is less effective (but still can be used)
for problems arising from an employee's lack of motivation
or lack of attention to the job. Whatever its purpose,
training is most effective when designed in relation
to the goals of the employer's total safety and health
If the problem is one that can be solved, in whole
or in part, by training, then the next step is to
determine what training is needed. For this, it is
necessary to identify what the employee is expected
to do and in what ways, if any, the employee's performance
is deficient. This information can be obtained by
conducting a job analysis which pinpoints what an
employee needs to know in order to perform a job.
When designing a new
training program, or preparing to instruct an employee
in an unfamiliar procedure or system, a job analysis
can be developed by examining engineering data on
new equipment or the safety data sheets on unfamiliar
substances. The content of the specific Federal or
State OSHA standards applicable to a business can
also provide direction in developing training content.
Another option is to conduct a Job Hazard Analysis
(see OSHA 3071, same title, 1987). This is a procedure
for studying and recording each step of a job, identifying
existing or potential hazards, and determining the
best way to perform the job in order to reduce or
eliminate the risks. Information obtained from a Job
Hazard Analysis can be used as the content for the
If an employee's learning
needs can be met by revising an existing training
program rather than developing a new one, or if the
employee already has some knowledge of the process
or system to be used, appropriate training content
can be developed through such means as:
- Using company accident
and injury records to identify how accidents occur
and what can be done to prevent them from recurring.
- Requesting employees
to provide, in writing and in their own words, descriptions
of their jobs. These should include the tasks performed
and the tools, materials and equipment used.
- Observing employees
at the worksite as they perform tasks, asking about
the work, and recording their answers.
- Examining similar
training programs offered by other companies in
the same industry, or obtaining suggestions from
such organizations as the National Safety Council
(which can provide information on Job Hazard Analysis),
the Bureau of Labor Statistics, OSHA-approved State
programs, OSHA full-service Area Offices, OSHA-funded
State consultative programs, or the OSHA Office
of Training and Education.
The employees themselves
can provide valuable information on the training they
need. Safety and health hazards can be identified
through the employees' responses to such questions
as whether anything about their jobs frightens them,
if they have had any near-miss incidents, if they
feel they are taking risks or if they believe that
their jobs involve hazardous operations or substances.
Once the kind of training
that is needed has been determined, it is equally
important to determine what kind of training is not
needed. Employees should be make aware of all the
steps involved in a task or procedure, but training
should focus on those steps on which improved performance
is needed. This avoids unnecessary training and tailors
the training to meet the needs of the employees.
Once the employees' training needs have been identified,
employers can then prepare objectives for the training.
Instructional objectives, if clearly stated, will
tell employers what they want their employees to do,
to do better, to stop doing.
Learning objectives do
not necessarily have to be written, but in order for
the training to be as successful as possible, clear
and measurable objectives should be thought-out before
the training begins. For an objective to be effective
it should identify as precisely as possible what the
individuals will do to demonstrate what they have
learned, or that the objective has been reached. They
should also describe the important conditions under
which the individual will demonstrate competence and
define what constitutes acceptable performance.
Using specific, action-oriented
language, the instructional objectives should describe
the preferred practice or skill and its observable
behavior. For example, rather than using the statement:
"The employee will understand how to use a respirator"
as an instructional objective, it would be better
to say: "The employee will be able to describe how
a respirator works and when it should be used." Objectives
are most effective when worded in sufficient detail
that other qualified persons can recognize when the
desired behavior is exhibited.
Once employers have stated precisely what the objectives
for the training program are, then learning activities
can be identified and described. Learning activities
enable employees to demonstrate that they have acquired
the desired skills and knowledge. To ensure that employees
transfer the skills or knowledge from the learning
activity to the job, the learning situation should
simulate the actual job as closely as possible. Thus,
employers may want to arrange the objectives and activities
in a sequence which corresponds to the order in which
the tasks are to be performed on the job, if a specific
process is to be learned. For instance, if an employee
must learn the beginning processes of using a machine,
the sequence might be (1) to check that the power
source is connected, (2) to ensure that the safety
devices are in place and are operative, (3) to know
when and how to throw the switch, and so on.
A few factors will help
to determine the type of learning activity to be incorporated
into the training. Once aspect is the training resources
available to the employer. Can a group training program
that uses an outside trainer and film be organized,
or should the employer personally train the employees
on a one-to-one basis? Another factor is the kind
of skills or knowledge to be learned. Is the learning
oriented toward physical skills (such as the use of
special tools) or toward metal processes and attitudes?
Such factors will influence the type of learning activity
designed by employers. The training activity can be
group-oriented, with lectures, role play, and demonstrations;
or designed for the individual as with self-paced
The determination of
methods and materials for the learning activity can
be as varied as the employer's imagination and available
resources will allow. The employer may want to use
charts, diagrams, manuals, slides, films, viewgraphs
(overhead transparencies), videotapes, audio tapes,
or simply blackboard and chalk, or any combination
of these and other instructional aids. Whatever the
method of instruction, the learning activities should
be developed in such a way that the employees can
clearly demonstrate that they have acquired the desired
skills or knowledge.
With the completion of the steps outlined above, the
employer is ready to begin conducting the training.
To the extent possible, the training should be presented
so that its organization and meaning are clear to
the employees. To do so, employers or supervisors
should (1) provide overviews of the material to be
learned; (2) relate, wherever possible, the new information
or skills to the employee's goals, interests, or experience;
and (3) reinforce what the employees learned by summarizing
the program's objectives and the key points of information
covered. These steps will assist employers in presenting
the training in a clear, unambiguous manner.
In addition to organizing
the content, employers must also develop the structure
and format of the training. The content developed
for the program, the nature of the workplace or other
training site, and the resources available for training
will help employers determine for themselves the frequency
of training activities, the length of the sessions,
the instructional techniques, and the individual(s)
best qualified to present the information.
In order to be motivated
to pay attention and learn the material that the employer
or supervisor is presenting, employees must be convinced
of the importance and relevance of the material. Among
the ways of developing motivation are (1) explaining
the goals and objectives of instruction; (2) relating
the training to the interests, skills, and experiences
of the employees; (3) outlining the main points to
be presented during the training session(s); and (4)
pointing out the benefits of training (e.g., the employee
will be better informed, more skilled, and thus more
valuable both on the job and on the labor market;
or the employee will, if he or she applies the skills
and knowledge learned, be able to work at reduced
An effective training
program allows employees to participate in the training
process and to practice their skills or knowledge.
This will help to ensure that they are learning the
required knowledge or skills and permit correction
if necessary. Employees can become involved in the
training process by participating in discussions,
asking questions, contributing their knowledge and
expertise, learning through hands-on experiences,
and through role-playing exercises.
To make sure that the training program is accomplishing
its goals, an evaluation of the training can be valuable.
Training should have, as one of its critical components,
a method of measuring the effectiveness of the training.
A plan for evaluating the training session(s) should
be developed when the course objectives and content
are developed. It should not be delayed until the
training has been completed. Evaluation will help
employers or supervisors determine the amount of learning
achieved and whether an employee's performance has
improved on the job. Among the methods of evaluating
- Student opinion.
Questionnaires or informal discussions with employees
can help employers determine the relevance and appropriateness
of the training program.
observations. Supervisors are in good positions
to observe an employee's performance both before
and after the training and note improvements or
improvements. The ultimate success of a
training program may be changes throughout the workplace
that result in reduced injury or accident rates.
However it is conducted,
an evaluation of training can give employers the information
necessary to decide whether or not the employees achieved
the desired results, and whether the training session
should be offered again at some future date.
If, after evaluation it is clear that the training
did not give the employees the level of knowledge
and skill that was expected, then it may be necessary
to revise the training program or provide periodic
retraining. At this point, asking questions of employees
and of those who conducted the training may be of
some help. Among the questions that could be asked
are (1) Were parts of the content already known and,
therefore, unnecessary? (2) What material was confusing
or distracting? (3) Was anything missing from the
program? (4) What did the employees learn, and what
did they fail to learn?
It may be necessary to
repeat steps in the training process, that is, to
return to the first steps and retrace one's way through
the training process. As the program is evaluated,
the employer should ask:
- If a job analysis
was conducted, was it accurate?
- Was any critical feature
of the job overlooked?
- Were the important
gaps in knowledge and skill included?
- Was material already
known by the employees intentionally omitted?
- Were the instructional
objectives presented clearly and concretely?
- Did the objectives
state the level of acceptable performance that was
expected of employees?
- Did the learning activity
simulate the actual job?
- Was the learning activity
appropriate for the kinds of knowledge and skills
required on the job?
- When the training
was presented, was the organization of the material
and its meanings made clear?
- Were the employees
motivated to learn?
- Were the employees
allowed to participate actively in the training
- Was the employer's
evaluation of the program thorough?
A critical examination
of the steps in the training process will help employers
to determine where course revision is necessary.
Training to Employees
While all employees are entitled to know as much as possible
about the safety and health hazards to which they are
exposed, and employers should attempt to provide all relevant
information and instruction to all employees, the resources
for such an effort frequently are not, or are not believed
to be, available. Thus, employers are often faced with
the problem of deciding who is in the greatest need of
information and instruction.
One way to differentiate
between employees who have priority needs for training
and those who do not is to identify employee populations
which are at higher levels of risk. The nature of the
work will provide an indication that such groups should
receive priority for information on occupational safety
and health risks.
One method of identifying employee populations at
high levels of occupational risk (and thus in greater
need of safety and health training) is to pinpoint
hazardous occupations. Even within industries which
are hazardous in general, there are some employees
who operate at greater risk than others. In other
cases the hazardousness of an occupation is influenced
by the conditions under which it is performed, such
as noise, heat or cold, or safety or health hazards
in the surrounding area. In these situations, employees
should be trained not only on how to perform their
job safely but also on how to operate within a hazardous
A second method of identifying
employee populations at high levels of risk is to
examine the incidence of accidents and injuries, both
within the company and within the industry. If employees
in certain occupational categories are experiencing
higher accident and injury rates than other employees,
training may be one way to reduce that rate. In addition,
thorough accident investigation can identify not only
specific employees who could benefit from training
but also identify company-wide training needs.
Research has identified
the following variables as being related to a disproportionate
share of injuries and illnesses at the worksite on
the part of employees:
- The age of the employee
(younger employees have higher incidence rates).
- The length of time
on the job (new employees have higher incidence
- The size of the firm
(in general terms, medium-sized firms have higher
incidence rates than smaller or larger firms).
- The type of work performed
(incidence and severity rates vary significantly
by Standard Industrial Classification, or SIC Code).
- The use of hazardous
substances (by SIC Code).
These variables should
be considered when identifying employee groups for
training in occupational safety and health.
In summary, information
is readily available to help employers identify which
employees should receive safety and health information,
education and training, and who should receive it
before others. Employers can request assistance in
obtaining information by contacting such organizations
as OSHA area Offices, the Bureau of Labor Statistics,
OSHA-approved State Programs, State on-site consultation
programs, the OSHA Office of Training and Education,
or local safety councils.
Determining the content of training for employee populations
at higher levels of risk is similar to determining
what any employee needs to know, but more emphasis
is placed on the requirements of the job and the possibility
of injury. One useful tool for determining training
content from job requirements is the Job Hazard Analysis
described earlier. This procedure examines each step
of a job, identifies existing or potential hazards,
and determines the best way to perform the job in
order to reduce or eliminate the hazards. Its key
- job description;
- job location;
- key steps (preferably
in the order in which they are performed);
- tools, machines and
- actual and potential
safety and health hazards associated with these
key job steps; and,
- safe and healthful
practices, apparel, and equipment required for each
In an attempt to assist employers with their occupational
health and safety training activities, OSHA has developed
a set of training guidelines in the form of a model. This
model is designed to help employers develop instructional
programs as part of their total education and training
effort. The model addresses the questions of who should
be trained, on what topics, and for what purposes. It
also helps employers determine how effective the program
has been and enables them to identify employees who are
in greatest need of education and training. The model
is general enough to be used in any area of occupational
safety and health training, and allows employers to determine
for themselves the content and format of training. Use
of this model in training activities is just one of many
ways that employers can comply with the OSHA standards
that relate to training and enhance the safety and health
of their employees.