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01/17/2023
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You must provide “effective” HazCom training to your employees at the time of their initial assignment and whenever a new physical or health hazard the employees have not previously been trained about is introduced into their work area. For example, if a new solvent is brought into the workplace, and it has hazards similar to existing chemicals for which training has already been conducted, then no new training is required. If the newly introduced solvent is a suspect carcinogen, and there has never been a carcinogenic hazard in the workplace before, then new training for carcinogenic hazards must be conducted for employees in those work areas where employees will be exposed.
There is no annual re-training requirement. During an OSHA inspection, however, the compliance officer will likely question employees regarding the HazCom program. If employees are unable to answer those questions, OSHA may determine that the employees are not adequately trained. Occasionally quizzing your employees about program elements may identify a need for refresher training.
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