Guide
HazCom Training Requirements: What Employees Must Learn
OSHA requires employers to train employees on the hazardous chemicals in their work area at the time of their initial assignment and whenever a new chemical hazard is introduced. Training must cover how to detect a release, the physical and health hazards, protective measures, and how to read labels and safety data sheets and where to find them.
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What the standard requires
Employee information and training is paragraph (h) of the HazCom standard. It requires employers to provide information on the standard itself, the operations in the work area where hazardous chemicals are present, and the location and availability of the written hazard communication program, the chemical list and the SDSs. Training must include:
- Methods and observations used to detect the presence or release of a hazardous chemical, such as monitoring, visual appearance or odor.
- The physical, health, simple asphyxiation, combustible dust and pyrophoric gas hazards, as well as hazards not otherwise classified.
- The measures employees can take to protect themselves: work practices, emergency procedures and personal protective equipment.
- The details of the hazard communication program, including the labeling system, the SDS (what the sections are and how to obtain and use the information).
When to train
- Before first working with hazardous chemicals at the time of initial assignment.
- When a new chemical hazard is introduced, meaning a new class of hazard, not simply another product with the same hazards.
- When new information significantly changes hazards or protective measures.
- Many employers also retrain annually as good practice, though the standard does not prescribe a refresher schedule.
Who needs it
Everyone who may be exposed to hazardous chemicals under normal conditions of use or in a foreseeable emergency: production, maintenance, cleaning, laboratory and warehouse staff, supervisors, and temporary or contract workers. Where several employers share a site, they must exchange information about the hazards and the location of sheets. See employee right to know.
A practical session outline
- Why it matters (5 min): relevant incidents or near-misses at your site.
- Labels (10 min): the six supplier label elements, workplace labels and secondary containers. See labeling and the pictogram reference.
- SDS walk-through (15 min): use a real sheet from the workplace. Find first aid, PPE, storage and spill advice. See how to read an SDS.
- Your chemicals (10 min): the inventory for the area and the top hazards.
- Protective measures (10 min): PPE selection and limits; see choosing gloves.
- Emergencies (10 min): spill, exposure, fire, evacuation, eyewash and shower locations.
- Questions and check: ask each person to find a fact on a sheet.
Documentation
OSHA does not prescribe a specific form for HazCom training records, but documenting who was trained, when, on what and by whom is the best way to demonstrate compliance. Keep the records with your written program and make them findable. Training must be in a language and at a level of vocabulary that employees understand. If your workforce speaks several languages, provide the training in each or use interpreters, and keep materials available in those languages.
Other training that sits next to HazCom
HazCom does not replace other training. Respirator users need respiratory protection program training and fit testing. Laboratory workers need training under the chemical hygiene plan (see the OSHA laboratory standard). People who prepare dangerous goods for transport need DOT hazmat training (see the DOT regulations). Emergency responders have their own requirements.
Worked scenario: training a new hire on the first day
A new warehouse operative starts on a Monday. Before they handle any chemical, the supervisor walks them through the chemicals in the work area using the inventory, shows them where the sheets and eyewash are, and explains the label pictograms using real containers. The operative is then asked to find the first-aid advice for one product on its sheet and to say what they would do after a splash. The supervisor records the date, the topics and the trainer, and notes that site-specific training on the forklift decanting station will follow on Wednesday.
This sequence covers the standard's topics and also shows that the training was tied to real products and not delivered in the abstract.
Refreshers and common gaps
- New hazards. When a product with a new type of hazard arrives, train before first use.
- Temporary and night-shift workers often miss training. Include them in the schedule.
- Training delivered only by video, with no chance to ask questions or look at real sheets, is a frequent weakness.
- Materials that are too technical for the audience, or not in a language workers understand.
Frequently asked questions
How often is HazCom training required?
OSHA requires it at initial assignment and when a new chemical hazard is introduced. There is no fixed annual requirement, but many employers retrain annually.
Does online training meet the requirement?
It can, as long as it covers the required topics and employees can ask questions of a qualified person, and the training is specific to workplace chemicals.
Do I have to train employees for each new product?
Not for each product, but for each new hazard. If a new product has hazards that employees have not been trained on, additional training is needed.
Must training be documented?
Not by a specific OSHA form, but keeping training records is the best way to demonstrate compliance.