Who Must Get the Training
All employees must receive effective hazard communication training. "Employees" are considered to be those who qualify for workers compensation in event
of injury or illness. This includes those paid through the University, plus visiting scientists and many volunteer workers who are part of a formal
volunteer worker program.
Students would not fall into this category (unless they're paid or otherwise qualify for workers compensation) but protective means should be equivalent
– i.e., class assignments should include research as to chemical hazards and students should receive training as to safe procedures, and how to correctly
use PPE and safety devices such as fume hoods.
Some categories of employees that you may have questions about are:
- Employees whose only "chemical exposure" would be when using items which are packaged as "consumer products" (such as pens, markers, furniture
polish, glass cleaner, etc.) and who use them similarly to typical consumer use: These employees must receive training about the UW HazCom program and their
rights when hired, and should receive a copy of the UW Brochure (pdf) during new employee orientation. However, if
the job entails more frequent use of chemicals, such as a person using art supplies to make posters on a weekly basis or a person assigned to clean items
all work shift using a common household cleanser, formal hazard communication training is needed. Supervisors of those workers intensively using
consumer-packaged chemicals must ensure training is completed as discussed below.
- Employees who do not routinely handle chemicals but often walk through the chemical work area: These employees must be trained as to the hazards of the
chemicals that are in use; how to don and doff and the limitations of any PPE required for everyone who enters the area; and, what to do if an emergency
were to occur.
- For work units where chemicals are stored but employees do not use them, employees still must be trained as to the possible hazards from the stored
chemicals and what to do in case of emergency. Additional training may be necessary if new items being stored present new hazards or require different
A poster describing the UW Chemical Hazard Communication Program must be posted on each departmental/unit safety bulletin board. Employees must be
informed of the location of the departmental/unit safety bulletin board, most commonly during new employee orientation.
Most of the work area specific chemical safety (HazCom) training requirements are one-time and initial (prior to exposure to a hazard), but some
requirements are annual. Periodic re-training about hazards and protective measures is not normally required. But, if employees demonstrate that they did
not retain the initial training, they need to receive re-training. Individual employee training must be effective to the point that the employee can:
- Identify the hazardous chemicals that are stored or used in the work area that may cause exposures for workers and bystanders. Ideally, the employee
would be knowledgeable enough to refer to the area’s chemical inventory as a means of remembering different types of hazards. (Initial)
- Recognize work processes that create exposures from materials that may not be in the MyChem inventory, such as melting glassware, sanding lumber,
conducting a field trip into a cave contaminated with guano, handling animals that may generate allergens, etc. (Initial)
- Get the appropriate Material Safety Data Sheet (MSDS) for any chemical used by that employee. The worker must be able to either retrieve an MSDS by
accessing MyChem or other electronic file, or by finding a paper copy in a local file, whichever method of MSDS storage is used by the work area. Each
person should be able to do this quickly, such as within five minutes, even if not fluent in English. (Initial)
- Identify the health hazards (e.g., carcinogens, irritants, etc.) and physical hazards (e.g., flammable chemicals, compressed gases, etc.) of the
hazardous chemicals in use. This could be from memory of a training session, by using information found on the chemical container label or in the
chemical's MSDS/SDS, or by referring to workplace guidance documents such as standard operating procedures or other available references. (Initial)
- Know the procedures and equipment to be used to lessen or prevent exposure to hazardous chemicals during different work tasks, including what should be
done in event of a spill or a failure of a protective device. Training in use of required personal protective equipment (PPE) such as gloves and eye
protection must be done in detail as described in APS 10.4 and supporting guidance material. Workers must be able to identify what PPE is required during
which tasks. Employees should refer to Standard Operating Procedures (SOPs) or Job Hazard Analyses (JHAs) when available. (Initial)
- Be able to relate how they would determine the presence or release of hazardous chemicals in the work area, such as by seeing a spill, smelling an odor,
hearing a hissing noise from a pressurized system, hearing an alarm from continuous monitoring equipment, or any other detection method that would signal a
chemical release. (Initial)
- Be able to tell the most likely symptoms which may result from an over-exposure to the chemicals used by the employee. The employees should know that
they can get a medical consultation at the UW Employee Health Clinic servicing their work area if they start to show symptoms of exposure, if a possible
over-exposure occurs such as during a spill clean-up, or if a measurement shows a level above a permissible exposure limit, (Initial)
- In laboratories where chemicals are manipulated, remember that WAC 296-828 (Appendix A in the Laboratory Safety Manual) and the laboratory’s Chemical
Hygiene Plan including SOPs provide the requirements for working safely with hazardous chemicals, and be able to retrieve the laboratory’s copies of these
documents. Employees also must be informed of any exposure limits (Washington State Permissible Exposure Limits – PELs – in WAC 296-841) or guideline limits
for the laboratory's chemicals, where additional references about laboratory chemical hazards can be found, and that EH&S can provide advice and
assistance for controlling exposures to hazardous chemicals. (Initial)
- In shops, offices, general industrial work areas, or other non-chemical-laboratory work areas, be able to refer to the UW Chemical Hazard Communication
poster on the safety bulletin board or otherwise be able to remember that WAC 296-800-170, UW APS 12.5 and supporting web pages provide information about
Chemical Hazard Communication. You should tell employees as to where these materials can be found on the web, or that EH&S can provide the documents.
EH&S should also be identified as providing advice and assistance for interpreting the documents and for monitoring exposures to hazardous chemicals.
Supervisors are also encouraged to make copies of the JHAs available to their employees that pertain to work tasks involving chemicals. (Initial)
- If processes cause airborne chemical levels to exceed permissible exposure limits or action levels, be informed annually of the chemical’s hazards and
the protective measures being used to reduce exposures. This annual training must continue until such time as process changes, improved ventilation or other
fixes are enough to lower levels to less than the exposure limit for that particular chemical. (Annual)
- Identify that EH&S maintains exposure monitoring records and they are available for review by workers or their representative. If the department or
work area has records of exposure monitoring, the employees must also be made aware of the existence of these records and their right to access them. By
regulation, workers should be reminded annually of these records and their right of access. (Initial and annual)
- Identify that employees have a right to access their medical records. By regulation, workers should be reminded annually of these records and their
right of access. (Initial and annual)
Additionally, all employees must complete annual training concerning asbestos hazards in the workplace. (Annual)
Many departments have described their training program in their departmental Health and Safety Plan.
Conducting the Training
Suggestions on how to conduct training are described in the following paragraphs and in the linked files. For the UW to meet the compliance criteria of
Labor & Industries inspectors, we must demonstrate a "good faith" effort to train employees about the hazards and required precautions to control the
hazards. You, as a supervisor, cannot simply give an MSDS or other reading materials to an employee and consider that sufficient – the employees must have a
reasonable opportunity to ask questions and learn the safety requirements in your work area, prior to the hazardous chemical use.
Training can be done through any route, for example:
- During new employee orientation,
- During formal classes,
- By noting prior training for a newly arrived employee,
- By documenting knowledge and experience demonstrated on-the-job, or
- By providing on-the-job training.
The trainer should document that training was done or that the employee demonstrated proficiency and did not need additional training, and note the date
and the training accomplished. If documenting proficiency, the trainer should check that the proficiency demonstrated covers all aspects of the tasks the
employee will be expected to perform.
The supervisor is the primary person responsible for making sure employees are trained. Any knowledgeable staff may perform the actual training. EH&S
offers some general information classes and a detailed class titled HazCom Train-the-Trainer class which provides information to familiarize an individual
with chemical hazards in order to teach others in the work area. For more information, visit the EH&S Training webpage.
Various training aids and devices are available to try to make things easier for training in the work area. One aid shows how chemicals may be grouped by hazard category (pdf). One or more of these categories could be covered in a
class. For example, if a work area has many chemicals that are “skin irritants,” they could be all identified, and the precautions for use and response to
take if an exposure occurs could be generalized. If any particular chemical in a group requires different precautions or response, it should be described
Another aid includes hints for how to set up your training.
After the initial training session(s), more training is required if new chemicals or processes having new hazards are introduced into the work area.
Periodic re-training is not required for most subjects, but refresher training may be necessary if you note that employees are not following procedures
correctly or not using protective measures properly.
If the work area receives products coming from manufacturers or suppliers that are using the Globally Harmonized System of Classification and Labeling of
Chemical Substances (GHS), personnel need training on the system. This system uses standardized signal words, pictograms, hazard statements, and
precautionary statements on their labels and SDSs to provide safety information.
Chemical producers use the system to classify chemicals into major hazard classes and categories which are related to specific signal words, pictograms,
hazard statements, and precautionary statements. The relationship between Hazard Class and Category, and the subsequent Signal Word and Pictogram is shown
in the following table.
|Hazard Class||Category Identifier(s)||Signal Word||Pictogram(s)|
|Acute Toxicity||1, 2, 3||Danger||Skull/Crossbones|
|Skin Corrosion||1A, 1B, 1C||Danger||Corrosion|
|Skin Irritation||2||Warning||Exclamation Mark|
|Eye Irritation||2A||Warning||Exclamation Mark|
|Respiratory Sensitization||1A, 1B||Danger||Health Hazard|
|Skin Sensitization||1A, 1B||Warning||Exclamation Mark|
|Germ Cell Mutagen||1A, 1B||Danger||Health Hazard|
|Carcinogen||1A, 1B||Danger||Health Hazard|
|Reproductive Toxicity||1A, 1B||Danger||Health Hazard|
|Specific Target Organ Toxicity, Single Exposure||1||Danger||Health Hazard|
|Specific Target Organ Toxicity, Repeated or Prolonged Exposures||1||Danger||Health Hazard|
|Aspiration Hazard||1||Danger||Health Hazard|
|Explosives||Unstable, 1.1, 1.2, 1.3||Danger||Exploding Bomb|
|Oxidizing Gases||1||Danger||Flame over Circle|
|Gases under Pressure||"Compressed", "Liquefied", "Refrigerated liquefied", "Dissolved"||Warning||Gas Cylinder|
|Flammable Liquid||1, 2||Danger||Flame|
|Self-Reactive Chemical||A||Danger||Exploding Bomb|
|B||Danger||Exploding Bomb, Flame|
|Chemicals which Emit Flammable Gases when in Contact with Water||1, 2||Danger||Flame|
|Oxidizing Liquid||1, 2||Danger||Flame over Circle|
|Oxidizing Solid||1, 2||Danger||Flame over Circle|
|Organic Peroxide||A||Danger||Exploding Bomb|
|B||Danger||Exploding Bomb, Flame|
|Corrosive to Metal||1||Warning||Corrosion|
1"Unclassified" means hazards that have not had a methodology developed yet for classifying severity, e.g., combustible dusts and asphyxiant gases.
The eight HazCom GHS pictograms are shown below. (Other pictograms showing environmental pollution and transportation concerns have also been
standardized but are not shown below.)
|Corrosion||Exploding Bomb||Flame||Flame over Circle
|Gas Cylinder||Health Hazard||Skull/Crossbones||Exclamation Mark
If these labels and Safety Data Sheets are provided on chemicals in your work area, everyone using the chemical must receive training as to the pictogram
meanings. For example, all workers should realize that a product labeled with a “Flame” (flammable) pictogram should not be stored in the same cabinet as a
product labeled with a ”Flame over Circle” (oxidizer) pictogram.
Personnel should also be trained to understand the hazard statements and to obey the precautionary statements. For example, the hazard statement for an
acutely toxic gas in category "1" is: "Fatal if inhaled". An example of one of the many precautionary statements for an acutely toxic gas is "If inhaled:
Remove victim to fresh air and keep at rest in a position comfortable for breathing."
Employee training records must be maintained for HazCom training. These records should include who was trained, the date of training, and the subject(s)
covered. Training materials should be retained in order to train new hires, to train those who missed the original training session, and to document the
scope of training.
Typically, supervisors are expected to maintain training records for each employee under their supervision, although some departments have designated
staff maintain the records. Training records should not be kept with personnel files and they need to be easily retrievable in case of a Labor and
Industries (L&I) inspection. Training records should be kept as long as an individual employee is working in that job, and may be retained longer if
there is a chance the employee may return to that job.
Suggested training documentation examples show ways to track training by class or subject: