GHS Questions – Questions – Questions!
At CLMI we have had hundreds of questions about GHS compliance these past several months, especially leading up to the December 1, 2013 deadline to provide GHS training. As one of the first SH&E professionals to create Right to Know / Haz Com training and compliance materials and provide training services, there aren’t many questions I haven’t had to answer. Most of the questions we are getting now revolve around the content of the GHS training for workers or how OSHA might enforce the new Standard. So I want to take a few minutes to explain some of the key elements of the revised OSHA Hazard Communication standard adopting the Global Harmonized System of Classification and Labeling of Chemicals. And then share a few training tips I’ve learned and practiced while training thousands of workers on Haz Com and now GHS.
First, with the GHS revisions you do not have to completely redo all of your Haz Com training. You do not have to reeducate workers about the Haz Com Standard and how to access information, nor retrain workers on the hazards of the chemicals they face, how to protect themselves, how to react in an emergency, etc. The training that you now have to provide must focus on the new GHS Labeling System and the revised Safety Data Sheet format.
Second, I have a feeling that OSHA is going to enforce the new GHS provisions a bit differently than before. On OSHA’s website under Hazard Communication, the say “The standard that gave workers the right to know, now gives them the right to understand.” I have heard Dr. David Michael say that the current Haz Com standard was about providing information and did little to verify that workers knew how to read and interpret this information. It seems that under new guidance OSHA Compliance Officers are going to be looking at the training provided and how learning was verified, and then check for understanding by talking with a sample of workers from different parts of the company. This could be problematic for those employers who follow the “plug and play” or “take the online course” and get back to work approach.
Tips for GHS Training Success
1. Choose the best training materials you can find. By this I mean make sure that the information is presented clearly and completely in any video, online course, PowerPoint, or other media. Be sure to check for accuracy and whether you notice any overly technical information that may confuse learners. Also, ask yourself whether you would find the training materials interesting and informative. You have many choices, so choose what’s best for your needs.
2. Make sure that the training about the GHS Labeling System is separated from that on Safety Data Sheets. When a person is introduced to the GHS labeling system it takes a while to comprehend and differentiate each pictogram and then understand the variety of detailed warning information that will accompany each one. It is like learning a new language; since the pictograms and many of the hazard categories and terms will be new, being able to quickly identify and explain them with accuracy will take practice.
3. Focus on helping individual workers learn the specific pictograms and hazard warning statements that apply to them, the chemicals they use and the work they do. After all, that is what really matters. The others pictograms must also be learned, but as Steven Covey wrote, “first things first”.
4. Consider adult learning principles, so try to make the training interesting and fun. Spice up the training experience. One way is to award little prizes, like candy or fruit for correct answers. Some trainers will use GHS flash cards to help workers learn. Some will create GHS bingo or other rapid response and association games. Anything that will increase interest and participation should be considered.
5. Remember that GHS is new and will take time and repetition to learn, so be sure to have follow up discussion and reenforcement activities built into the training plan. Don’t rely on the DVD or online course to do all the teaching! Use posters, booklets, handcards, and other props. Create short tool box talks about the pictograms, or a series of reminders in the company newsletter or employee website.
6. Teaching about the new Safety Data Sheet format is not as complicated. To help workers learn the new categories or sections provide a learning exercise that requires them go through a sample SDS to find specific information. Have them do this a few times, varying the information they need to find.
7. To reinforce the full Haz Com training that was provided earlier, build a bridge between that and the new GHS system. One idea involves a work group or team setting. Provide each person the specific SDSs for the chemicals to which they may be exposed. Then, ask each worker on the team to find a piece of information about one of the chemicals from one of the SDSs and share it. Pick the most important information based on the hazards of the various chemicals; like for a material that is highly flammable ask for information on how to control the fire hazard and what to do in an emergency. This activity help reinforce previously learned information and teaches how to read and interpret information from the new SDS format.
8. Follow up several months later with short group activities, like having the workers go through a quick recognition exercise. If they are good at remembering what the pictograms are and how to protect themselves, they understand. If not, it tells you that your training fell short and that more follow-up is required.
I hope these tips are helpful and will increase learning and understanding. Afterall, it is all about the level of comprehension and understanding by each individual worker that most important. This time around it appears that OSHA wants a higher level of learning to take place, and that’s OK if you know what and how to get to that level. Please let me know if these tips were helpful, and don’t hesitate to contact any of us at CLMI if you have any more questions. Successful training!