• If an employee has not received training or is not adequately trained, the employer who provides the day-to-day supervision of the employee will be held responsible.
• No formal certification is required to conduct HazCom training.
• Records of employee training are not required by the HazCom standard but are recommended.

The controlling employer is responsible

The employer who provides the day-to-day supervision of the employee is ultimately responsible for ensuring that workers are adequately trained.

The experience provided by a previous employer or other entity may relieve an employer of some of the burdens of training that worker. So long as training is adequate, general training may be provided by:

• The current employer
• A past employer
• An employee union
• Any other entity

If an employee has not received training or is not adequately trained, the current employer will be held responsible regardless of who trained that particular employee.

The Occupational Safety and Health Administration (OSHA) does not specify who can conduct HazCom training, nor is any formal certification required to do so.

The trainer must be familiar with:

• The requirements of the standard that apply to the workplace;
• The hazardous chemicals in the workplace to which workers are potentially exposed, as well as the types of hazards they pose;
• The hazard communication program implemented in the workplace; and
• The protective measures being employed in the workplace to prevent adverse effects from occurring.

In addition to being thoroughly familiar with the material to be covered in the training, the trainer should be aware of the facilities available for the training, including the physical location, the type of equipment (e.g., a PowerPoint projector, computer), and plan the training session accordingly based on the conditions.

The employer may determine who is qualified to do training. Whoever does the chemical-specific training should be familiar with the safe handling requirements of those chemicals.

Documentation

It is an industry best practice to maintain records of HazCom training, although the standard does not require it. By keeping training records the employer can ensure that all employees have received appropriate and timely training as needed. Companies can also demonstrate to the Occupational Safety and Health Administration (OSHA) that they are complying with the training requirement.