Sue - Glenn says an interactive "video" is fine, and the online class DOES require participants to correctly answer questions to ensure a basic understanding of the materials which is what the Q and A part is intended to do. The message below says the Q and A part should take place, but I don't see it as a requirement as long as the program is interactive and ensures basic understanding of participants. If you are concerned about the Q and A part, just make sure participants communicate any question to you in some format so that you may research the answers and get back to them. That's my take. Maria From: CORSA-broadcast [mailto:corsa-broadcast-bounces@corsa.org] On Behalf Of sue bommer Sent: Wednesday, October 30, 2013 9:07 AM To: CORSA Broadcast Ema Subject: Re: [CORSA-broadcast] HazMat Global Systems Training Thanks very much, Maria. I do have one question, though. Since an opportunity for Q & A is part of the training requirement, how does watching the online video suffice? Thanks, Sue On Wed, Oct 30, 2013 at 8:12 AM, Maria Rupert <MRupert@eriecounty.oh.gov<mailto:MRupert@eriecounty.oh.gov>> wrote: Sue - the communication below will answer some of your questions. This was forwarded to CLCCA members some time ago. The BWC also has a 30 minute online class on the topic that is very informative, (but a little corny) and will suffice as the required training. For Erie County employees who aren't doing the online training (our facilities and custodians are doing the online class in a group setting), I am presenting a 45 minute class that includes a video from the BWC. Ms. Rupert: You recently submitted several questions regarding compliance requirements in the 2012 Hazard Communication (HAZCOM) standard 29 CFR 1910.1200. It is important to note that while this standard was updated in 2012, many of the fundamental requirements in the standard remain unchanged from the original standard as promulgated in 1994<https://www.osha.gov/dsg/hazcom/hazcom_1994.html> by the United States Department of Labor (USDOL), Occupational Safety and Health Administration (OSHA) and adopted as an Ohio Employment Risk Reduction Standard<http://codes.ohio.gov/oac/4167-3> by the Ohio Public Employment Risk Reduction Program (PERRP) in 1994. Your paraphrased questions concerning the updated standard and our responses follow. Question: It is my understanding that the only HAZCOM deadline in 2013 employers must meet is a requirement to provide employees with information and training on the new HAZCOM label requirements (including the symbols) as well as the new layout of the SDSs by December 01. Is that correct? Answer: You are correct. By December 01, 2013, employers must provide training to employees on the new HAZCOM labeling elements and the new Safety Data Sheet (SDS) format. Employers are required to provide this training now because they may already be receiving chemicals with new labels and Safety Data Sheets. Existing employee training and information requirements in paragraph (h)<https://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=STANDARDS&p_i...> of the standard continue to remain in effect and have not changed. Question: Are employers required to provide the required information in a classroom training session? Or can they provide written materials to employees to meet the training requirement? Answer: Employers are required to provide training on the new requirements to affected employees. Training cannot be accomplished by providing written materials to employees for their review. 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. OSHA has created two very good fact sheets on the new labeling requirements and the new SDS format that employers can use during their employee training. Here are links to the fact sheets: OSHA Brief on Labels and Pictograms: https://www.osha.gov/Publications/OSHA3636.pdf OSHA Brief on Safety Data Sheets: https://www.osha.gov/Publications/OSHA3514.pdf OSHA has also created downloadable images of the required pictograms employers may use for in-house (secondary) container labels or for training: https://www.osha.gov/dsg/hazcom/pictograms/index.html Employers are encouraged to make use of educational materials produced by the USDOL as they revise their written program and conduct employee training. Question: Are employers required to provide this training to office workers and other employees that are not expected to use or be exposed to hazardous chemicals during their assigned routine daily work tasks? Answer: No. Employers are only required to provide HAZCOM training to employees who will be assigned to work with or will be exposed to hazardous chemicals under normal operating conditions or in a foreseeable emergency. The HAZCOM standard defines an employee as: "Employee means a worker who may be exposed to hazardous chemicals under normal operating conditions or in foreseeable emergencies. Workers such as office workers or bank tellers who encounter hazardous chemicals only in non-routine, isolated instances are not covered." "Foreseeable emergency means any potential occurrence such as, but not limited to, equipment failure, rupture of containers, or failure of control equipment which could result in an uncontrolled release of a hazardous chemical into the workplace." The majority of definitions in paragraph (c)<https://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=STANDARDS&p_i...> of the standard including the definitions of "employee" and "foreseeable emergency" have not changed since the standard was originally promulgated in 1994. Question: Are employers required to update their written HAZCOM program in 2013? Answer: No. Here are the compliance dates<https://www.osha.gov/dsg/hazcom/hazcom-faq.html#3> for the standard: Effective Completion Date Requirement(s) Who December 1, 2013 Train employees on the new label elements and safety data sheet (SDS) format. Employers June 1, 2015* December 1, 2015 Compliance with all modified provisions of this final rule, except: The Distributor shall not ship containers labeled by the chemical manufacturer or importer unless it is a GHS label Chemical manufacturers, importers, distributors and employers June 1, 2016 Update alternative workplace labeling and hazard communication program as necessary, and provide additional employee training for newly identified physical or health hazards. Employers Transition Period to the effective completion dates noted above May comply with either 29 CFR 1910.1200 (the final standard), or the current standard, or both Chemical manufacturers, importers, distributors, and employers As noted above, employers must be in full compliance with all provisions of the new standard by June 01, 2015. However, employers are not required to update their written HAZCOM program until June 01, 2016. The additional year was granted for updating the required written program because manufacturers also have until June 01, 2015 to complete a reevaluation of their chemical hazards and update their Safety Data Sheets and labeling information. Distributors are allowed to ship existing chemical stocks with old labels and Material Safety Data Sheets up until December 01, 2015. Therefore, it is possible, employers may not start to receive new labels and Safety Data Sheets for some products until early in 2016. Employers will have seven months from December 01, 2015 and June 01, 2016 to examine all new Safety Data Sheets and chemical labels to see if they need to update their written HAZCOM program. Employers must then, as necessary, update any alternative workplace labeling used under paragraph (f)(6)<https://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=STANDARDS&p_i...> of the standard, update the hazard communication program required by paragraph (e)<https://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=STANDARDS&p_i...>, and provide any additional employee training in accordance with paragraph (h)(3)<https://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=STANDARDS&p_i...> for newly identified physical or health hazards no later than June 1, 2016. The fundamental requirements for a written program and training have not changed in the 2012 revision of the standard. Employers have always been required to train employees on label elements and other hazard information (e.g., MSDS content). One existing requirement for a written program and employee training is that must explain how the employer will label chemicals in-house. For example, how spray bottles and other secondary containers filled in the workplace will be labeled. Employers may know how their labeling will be affected prior to December 1, 2015, but, they will not know for sure until they have received new Safety Data Sheets and labels from their chemical distributors. Since manufacturers are required to update their labels and create new Safety Data Sheets by June 1, 2015, employers could contact chemical manufacturers directly for the new information prior to receiving new shipments of chemicals they will continue to purchase and use. In reality, employers have one year from June 01, 2015 to June 01, 2016 to gather new Safety Data Sheets, labeling information, update their written program and provide employees with updated training. This is a phased in standard. Employers can choose to fully implement the standard now, or wait to implement the new provisions when the deadlines arrive. Please pass this along to other members of the County Loss Control Coordinators Association (CLCCA) or other public employers required to comply with the adopted standard. If anyone has any questions, they can call 1-800-6711-6858 to speak with the PERRP Compliance Investigator assigned to their area. If you have any questions, don't hesitate to contact us. Glenn McGinley Program Director Ohio Public Employment Risk Reduction Program (PERRP) 13430 Yarmouth Drive Pickerington, OH 43147 Toll Free: 800-671-6858<tel:800-671-6858> FAX: 614-644-3133<tel:614-644-3133> [cid:image001.jpg@01CED558.52C53FA0]<http://www.ohiobwc.com/> From: CORSA-broadcast [mailto:corsa-broadcast-bounces@corsa.org<mailto:corsa-broadcast-bounces@corsa.org>] On Behalf Of sue bommer Sent: Tuesday, October 29, 2013 12:59 PM To: corsa-broadcast@corsa.org<mailto:corsa-broadcast@corsa.org> Subject: [CORSA-broadcast] HazMat Global Systems Training Will you please broadcast the following: I am interested in knowing how other counties have done or are doing their mandatory hazmat training. For example, did you use an outside trainer or video, did you do it online, or did you design and present your own program? Also, did you train all employees or only those who regularly come in contact with hazardous materials? Any information you can share with me will be greatly appreciated. Thank you, Sue -- Sue E. Bommer, M.Ed., SPHR Huron County Director of Human Resources and Loss Prevention 12 E. Main St., Suite 102 Norwalk, OH 44857 419-668-6262<tel:419-668-6262> Fax: 419-668-2095<tel:419-668-2095> _______________________________________________ CORSA Broadcast Email To unsubscribe, go to http://corsa.org/mailman/listinfo/info_corsa-broadcast.org -- Sue E. Bommer, M.Ed., SPHR Huron County Director of Human Resources and Loss Prevention 12 E. Main St., Suite 102 Norwalk, OH 44857 419-668-6262 Fax: 419-668-2095
