With the final GHS compliance deadline nearly two months old, OSHA expects every company to be in perfect compliance with the new standard. With the recent civil fines hike, non-compliance will be more costly than ever before. If you want to avoid fines, you’d better make sure you meet every GHS requirement.
These requirements include updated SDSs, chemical inventory lists, and containers on labels. We’ve talked about each of those aspects of compliance on this blog before; today we want to talk about training.
GHS training might seem like old news to you, but many employers have failed to keep up with their training obligations under HazCom 2012. These employers saw the GHS training deadline as a one-time obstacle rather than an ongoing project. If you haven’t given your workers a refresher course in GHS, you might already be out of compliance.
Keeping Up With GHS Training
OSHA expects every employee to be able to recall the basic elements of GHS. Inspectors usually test this by asking your workers some simple questions about your HazCom plan. If you don’t think your employees will pass this kind of inspection, you should take that as a cue to schedule more training.
If you’re planning on shoring up your GHS training regimen, here are some common pitfalls to avoid:
Some employees were either never given or have forgotten large portions of their basic HazCom training. Without this background knowledge, they found it very difficult to put GHS’s changes into context. To avoid this problem, make sure your personnel know the rudiments of HazCom before moving onto the details.
GHS has a lot of little fiddly rules that can be difficult to fully memorize. Without regular refresher classes, your employees might forget portions of their training. Unless you want your training to be forgotten, you should schedule refreshers every year or so.
The United Nations puts out a new version of GHS every other year, and American regulators have stated that they plan on periodically updating HazCom to match the UN’s standard. This means that before too long we’ll be seeing more regulatory changes in the US. You’ll have to keep your employees up-to-date if you don’t want to fall out of compliance.
If you follow those tips, you should be able to get the most out of your HazCom training program. Hold a thorough refresher course every 12 to 18 months, and make sure your employees have references available if they want to look something up on their own. I’ll be sure to inform you of any changes to HazCom, so be sure to check this blog periodically.
