How will OSHA judge if my HazCom training is effective?

OSHA compliance officers will usually talk to employees to determine if they have received training, if they know they are exposed to hazardous chemicals, and if they know where to obtain substance-specific information on labels and SDSs.

OSHA says that they do not expect that every worker will be able to recite all the information about each chemical in the workplace or recall all the information that was provided in training.

OSHA does expect that employees would know that they are exposed to hazardous chemicals, that they know how to read and use labels and safety data sheets, and that, as a consequence of learning this information, they are following the appropriate protective measures established by the employer.

If the compliance officers detects a trend in employee responses that indicates training is not being conducted, or is conducted in a cursory fashion that does not meet the intent of the standard, he or she will take a closer look at the written program and how it is implemented.

The written HazCom program should provide enough details about the employer's HazCom training so that a Compliance Officer can assess whether or not a good faith effort is being made to train employees.

The rule does not require employers to maintain records of employee training, but many employers choose to do so. This may help you monitor your own program to ensure that you have trained all employees appropriately.