Fewer than 20 words. In the 320-plus-page rulemaking on Globally Harmonized Systems (GHS), that is how many words OSHA devoted to the most extensive new training requirement companies face in 2013. That change requires every affected U.S. company to train its workers on the new update to the Hazard Communication Standard. OSHA estimates that the GHS training will cost American industry more than $95 million dollars.
The GHS rulemaking is the result of more than two decades of international negotiation and national discussion aimed at creating one worldwide standard for the classification and labeling of hazardous chemicals in the workplace. OSHA released the final rule mandating GHS in the United States back in March 2012 and, buried there between page 17,574 and page 17,896 of the Federal Register is one sentence: “Employers shall train employees regarding the new label elements and safety data sheets format by December 1, 2013.”
As one of the leading companies providing safety training to the oil and gas industry, those few words resulted in hours of analysis and internal debate. To some extent, GHS is a tradeoff – meeting the worker’s right to know about hazardous chemicals in the workplace vs. the employer’s obligation to not bombard workers with more information than they can absorb or use.
The first question we had to answer was: What is our goal here? If the goal is create a compliance-based course that allows companies to check a box with OSHA, teaching the changes to the hazcom standard are simple: show the label, show the pictogram, show the safety data sheet, give a test and get everyone back to work. That would probably take about 15 minutes.
But as instructors, we have to aim higher. This is information can save a worker’s life. We need to prepare workers to use the new GHS format in an emergency. We need to give them the right amount of information to meet their needs.
Once again, explaining the new labeling pictograms and Safety Data Sheets (SDS) is easy, but only if the student already understands the current hazcom system. The trouble is, how many workers actually had appropriate hazcom training? Twenty years in the training business told us the answer was probably “not many.” Factor in that a lot of workers had their training a long time ago and we realized that most workers lack the understanding of hazcom to put the GHS update into context. So first we had to make sure our GHS update had a healthy dose of hazcom refresher training.
GHS Training: A Few Words Speak Volumes