• Training needs to be provided at no cost to the employees, and employees must be paid for the time they spend in training.
• After the training, workers should understand how to read labels and SDSs, understand what information is in these documents, and understand how to access them.
• Training must be provided prior to the initial job assignment.

Information and training may be done either by individual chemical, or by categories of hazards, such as flammability or carcinogenicity. If there are only a few chemicals in the workplace, then an employer may want to discuss each one individually. Where there are large numbers of chemicals, or the chemicals change frequently, training based on the hazard categories such as flammable liquids, corrosive materials, or carcinogens may make more sense.

Training must be provided at no cost to the employees, and employees must be paid for the time they spend in training.

Focus on the specific chemical hazards in the workplace. Explain:

• How to detect the presence or release of the chemical;
• The visual appearance or odor when the chemical is being released;
• How any monitoring devices work and what they indicate;
• The physical and health effects of the chemicals;
• What first aid measures should be used in the event of exposure or overexposure, and
• Where on the safety data sheet (SDS) this information can be found.

The Occupational Safety and Health Administration (OSHA) does not expect that workers will be able to recall and recite all data provided about each hazardous chemical in the workplace. What is most important is that workers understand that they are exposed to hazardous chemicals, know how to read labels and SDSs, and have a general understanding of what information is provided in these documents, and how to access these tools.

When to train

Prior to the initial job assignment, each employee who has exposure risks to hazardous chemicals must be provided information and training. Additional training must be done whenever a new physical or health hazard is introduced into their work area.

Training temporary workers/contract employees

The responsibility for training temporary or contract employees is shared between the employment agency and the host employer. The employment agency has the primary responsibility to provide generic HazCom information and training to their employees. This should include information on labels and other forms of warning, the format and content of SDSs, and other employee information and training required by the HazCom Standard.

The contracting employer is responsible for providing site-specific training and has the primary responsibility to control potential exposure conditions. This training should include identifying and communicating information about site-specific chemical hazards, ensuring appropriate labeling of chemical containers, providing access to SDSs, and providing appropriate personal protective equipment (PPE). The HazCom training provided to temporary workers should be identical or equivalent to the training given to the host employers’ own employees.

As a recommended practice, the employment agency and contracting employer should discuss responsibility for each aspect of HazCom training and inform the other employer when the training is completed. The details of the particular training to be performed can be clearly stated in the language of the contract between the employers and in the host employer’s written HazCom program.