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It is not necessary that an employer retrain each new hire if that employee has received prior training by a past employer, an employee union, or any other entity. General information, such as the rudiments of the HazCom standard could be expected to remain with an employee from one position to another. The employer, however, maintains the responsibility to ensure that their employees are adequately trained and are equipped with the knowledge and information necessary to conduct their jobs safely.
As such, it is likely that additional training will be needed since employees must know the specifics of their new employers’ programs such as where the SDSs are located, details of the employer’s in-plant labeling system if it is different than that required by the standard, and the hazards of new chemicals to which they will be exposed. For example, 1910.1200(h)(3)(iii) requires that employees be trained on the measures they can take to protect themselves from hazards, including specific procedures the employer has implemented such as work practices, emergency procedures, and personal protective equipment to be used. An employer, therefore, has a responsibility to evaluate an employee’s level of knowledge with regard to the hazards in the workplace, their familiarity with the requirements of the standard, and the employer’s hazard communication program.