• Include all employees who are exposed to hazardous chemicals in the training.
• Thorough training and understanding of the HazCom standard can help maintain compliance.

Employers must train all employees who are exposed to hazardous chemicals in their work area before they are initially assigned to those jobs.

“Exposure” or “exposed” means that “an employee is subjected to a hazardous chemical in the course of employment through any route of entry (inhalation, ingestion, skin contact or absorption, etc.) and includes accidental or possible exposure.”

If there are some employees who are occasionally in an area where chemicals are stored or used, and it is undecided whether they are “exposed,” include them in the training program. Those employees who encounter hazardous chemicals only in non-routine, isolated instances would not have to receive training.

Summary of requirements

Employees must be informed of:

• The requirements of the HazCom standard;
• The operations in their work area where hazardous chemicals are present; and
• The location and availability of the written hazard communication program, including the list of hazardous chemicals, and safety data sheets (SDSs).

Training must address:

• Methods and observations used to detect the presence or release of a hazardous chemical in the work area (such as monitoring conducted by the employer, continuous monitoring devices, visual appearance or odor of hazardous chemicals when being released, etc.);
• The physical and health hazards of the chemicals in the work area;
• Measures workers can take to protect themselves from these hazards, work practices and other measures the employer has implemented to protect workers from exposure to hazardous chemicals, such as emergency procedures, and personal protective equipment to be used; and
• An explanation of and the details of the workplace hazard communication program, the labeling system and the SDS, and how workers can obtain and use the appropriate information.