New Materials for Revised OSHA Hazard Communication Standard

1. New Materials on Revised OSHA Hazard Communication StandardRobert Weeks, Ph.D, CIH DOE and DOE Contractors Industrial Hygiene Meeting in Conjunction with the 2013 American Industrrial Hygiene Conference and Exposition

2. On March 26, 2013 the revised HAZCOM standard was published and it became effective on May 25, 2013 • Soon thereafter the committee established responsibilities for proceeding with the generation of training materials for both “live” and “online” • Two sub-groups were established, one dealt with examining the new standard and summarizing the pictogram, label and safety data sheet “technical aspects” and the second used their findings to generate questions

3. Upshot • New Training Materials for Revised OSHA Hazard Communication Standard (29 CFR 1910.1200, March 26, 2012) • Materials prepared under the aegis of EFCOG • EFCOG (Energy Facility Contractors Group) was established in 1991. • EFCOG Mission: Reduce DOE program costs and increase aggregate contractor performance

4. This EFCOG GHS group came together during the spring of 2012 and the purpose was to develop GHS training material that could be used throughout the DOE Complex by fine tuning for each site. • The group came together being aware that OSHA was going to publish a revised HAZCOM standard that would be consistent with the UN Globally Harmonized System (GHS) • But,… the group did not know when the new HAZCOM standard would be published in the Federal Register nor when it would become effective

5. Perhaps the most nearby time requirement is that prior to December 1, 2013 all workers who either are or have the possibility of being exposed to hazardous materials must be trained such that they are aware of the meaning of: Pictograms The requirements for a label and what information one can get from a label. The format of a safety data sheet and the information presented in each of the 16 sections of the SDS.

6. What may be considered the cornerstone for HCS-GHS training throughout the complex is the EFCOG GHS course. When the contents of the course are taught in a timely fashion the training requirements of 29 CFR 1910.1200 meet the March 26, 2012 requirements. • The course includes a Dr. Michaels introduction to why the HCS-GHS was necessary, ongoing questions throughout the course and class exercises. The recommended time frame for the class is four hours but that can be tailored to the needs of the site.

7. Examples of Fine Tuning the Training • The cornerstone of our HCS-GHS training is the EFCOG work. We have modified it two way: • HCS-GHS lanyard cards so that workers will wear these and can simply look at the card if there are questions regarding the meaning of pictograms. • The use of “electronic clickers” during lectures. This is a device in which a multiple choice question is posed on the screen during lecture. Each trainee has an electronic device by which they can pick an answer and after each person has answered the question the results are electronically summarized and posted on the screen. • The instructor can then see if the particular topic has “soaked in” and if not can go over it again.

9. As the training material developed, the need for the committee members to communicate became rather evident and Deborah McFalls and Jennifer Hendricks of Oak Ridge established a SharePoint site for posting of the evolving training material. • This public GHS site is: • http://orise.orau.gov/ihos/hottopics/training.htm