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The Occupational Safety and Health Administration (OSHA) frequently cites employers for failing to adequately train employees who work with chemicals. The regulation on training contains three requirements:

  1. Train employees on hazardous chemicals upon assigning job tasks involving hazardous chemicals,
  2. Provide additional training whenever new chemical hazards are introduced, and
  3. Ensure that chemical information is available through Safety Data Sheets (SDSs) and labels on containers.

The following outlines common situations that may result in violations.

Initial training

Employees who work with hazardous substances need training to keep themselves safe. If employers are not aware of their obligations and fail to provide initial training, when OSHA inspectors arrive, the company could be cited.

Some violations occur when employees transfer to a new area or take over new responsibilities, but do not receive training. If the employer doesn’t identify all employees who need training, some workers may be trained but others are not.

Another problem occurs when employees receive training but cannot answer an OSHA inspector’s questions about chemical hazards. If employees don’t remember key information from their training, OSHA may use that as evidence of a lack of training.

New hazards

One option for when a new chemical hazard is introduced is that employers could deliver training that covers categories of hazards (such as flammability), or they could provide training on the specific chemicals used. If employees work with relatively few chemicals, training might focus only on those chemicals. However, that may mean employers need to provide more training when a new chemical is introduced.

If employees start using a new chemical, verify that their training covers the particular hazards of that substance.