Who must train contract employees under the Hazard Communication standard?

Where there is more than one employer operating on a site, the host employer's written hazard communication program must address:

• How onsite access to safety data sheets will be provided to the other employer(s);
• How other employers will be informed of needed precautionary measures; and
• How other employers will be informed of the onsite labeling system if it is different from the labels specified for shipped containers under the standard.

This will allow the contract employer to train its own contract employees in any new chemical hazards. However, the contractor and host employer may share responsibility to provide training to contract employees if the host employer is a creating, exposing, correcting, or controlling employer per OSHA directive CPL 02-00-124. In that case, the contract between the contractor and the host employer should spell out who would be expected to provide generic and/or site-specific HazCom training. Often the contractor provides generic training, while the host employer provides site-specific HazCom training for chemicals found at the site.