Hazard Communication "Employee Right to Know"
The Hazard Communication (HAZCOM) Program, also referred to as 'Employee's Right to Know', is required by OSHA for all facilities using
'hazardous chemicals'. This program is designed to inform employees of the hazards of the chemicals they work with and how to take appropriate
precautions. Failure to have a written HAZCOM program is the number one item most often cited by OSHA. Training is required prior to the first
day of work for an employee as well as refresher training (annual is recommended).
This program includes the written program itself as well as training materials. The training materials include Instructor and Student Guides,
tests, answer sheets, certificates and videos. Since OSHA expects your employees to truly understand the hazards of using your plant's
chemical products, our training materials thoroughly teach how to read and understand the new GHS Safety Data Sheet, including all of the chemical terminology.
Also included are all the current Safety Data Sheets (SDS) that appear on your Chemical List. Employees are to be trained on how to
access and read these SDSs so they will know the hazards associated with using these chemicals and what steps they should take to protect
themselves. For instance, do they need to wear protective gloves and/or eye protection? If so, exactly what kind of gloves and eye protection
should they wear? NOTE: OSHA regulations require that your facility maintain current copies of SDSs for all the hazardous chemicals you have
at your location. Also, these regulations required that all containers, including secondary containers, be labeled with Manufacturer's Name,
Product Name and an Appropriate Hazard Warning, including the GHS required signal word and precautionary statements. For those ACS customers
who subscribe to our Online Automated SDS Support Service, we provide free-of charge OSHA compliant labels for use on their secondary containers.
Our program also includes, for our California customers, the current Prop 65 listing. The Prop 65 listing is the list of substances known to the
state of California to either cause cancer or reproductive harm.
Forklift Training and Certification
The Federal Forklift Rule, as of December 1999, changed to require more comprehensive training including both Classroom and Operational training.
In California, the new forklift training and certification rules became effective on July 15th, 2000. All states now require for this comprehensive
motorized lift truck training program to be fully implemented for all lift truck operators. Not less than every three years operators must be
retrained/certified as competent motorized lift truck operators.
One way companies implement this program is to have ACS train one or two employees in a 'Train the Trainer' training class. Your in-house trainers
will be trained and certified by an ACS consultant. When this is accomplished, your trainers will use our materials to train the other drivers in
Another way your company can satisfy the OSHA Forklift training requirement would be to have an ACS consultant perform the classroom training for
all of your driver/operators, including your in-house trainers. Following the classroom training session, your in-house trainers would go to your
forklift with the ACS consultant and 'Operational Training' would be conducted for your in-house trainers. This operational training is essentially
a 'driving test' based on your specific location. Following the successful completion of this operational training, your in-house trainers will be
competent to conduct both classroom and operational training certification classes (using ACS training materials) for all the rest of your
drivers/operators. And, when new employees are hired, your own in-house trainers will now be able to complete the motorized lift truck training
for those new employees without having to pay an outside consulting company to conduct the training.
This program includes Trainer's Guide, Student Guides, testing materials, answer sheets, operational certification checklists, videos, and
certificates. The operational training will naturally be completed 'hands on'.
There are two types of operator training certificates. One is the 'Classroom Training Certificate' and the other is an 'Operational Training
Certificate'. The classroom certificate is earned by successfully completing the class and passing the written test. The operational certificate
is earned when employees successfully complete an actual driver's training test given by your in house instructors.
A fancy 'Forklift Train the Trainer Certificate' is awarded to each of your in-house trainers that are certified as trainers by Assured Compliance
Another important OSHA required program is Lockout/Tagout (LO/TO). LO/TO is a set of procedures that OSHA wants a company to follow so that their
employees maintain and service their equipment in a safe manner. These procedures should "prevent the unexpected startup of equipment", thereby
hopefully preventing accidents and injuries. The training is conducted based on the category of employee, i.e. Authorized, Affected, and other.
Authorized Employee- Supervisors and technicians who physically perform the LO/TO procedures.
Affected Employee- Machine operators who are affected if a LO/TO procedure is implemented.
Other Employees- Peripheral people who may have casual contact with the equipment.
Our program includes the required written program as well as training materials including videos. This program does not include actual locks
and tags. These locks and tags can be purchased from companies like Lab Safety, Granger, or your local safety supplies vendor. This part of the
regulations concerning LO/TO require that you have written procedures specific to each machine that requires Lockout or Tagout. In our training
class, we cover how to write these procedures. And after the written test has been completed, we take the class out to the production floor and we
show your employees where locks and tags should be placed on your specific plant machines. Your employees should now fully understand the correct implementation of
Lockout/Tagout, and you can assign specific machine procedure writing duties to some of your trusted employees. OSHA does expect to see specific
written Lockout/Tagout procedures in place for each of your plant machines.
Injury and Illness Prevention / Accident Prevention / Workplace Safety / Health & Safety
Many states including California, Oregon and Washington require an "Injury and Illness Prevention Program, also called Accident Prevention, Workplace
Safety, or Health & Safety Program. Although not OSHA required in every state, this program is the cornerstone of a quality safety program and its'
implementation is essential for your company to have the safest possible operation. Our experience indicates that a high percentage of serious accidents
are due in part or totally to employees breaking one or more safety rules from the code of safe practices contained in this program. Our injury and
Illness Prevention Program gives detailed information concerning the following areas:
- Safety Policy
- Code of Safe Practices
- Disciplinary Action
- Accident Investigation
- Hazard Assessment
- Safety Committee Guidelines
The program includes training materials which consist of Trainer's/Instructors Guide and Student Guides as well as videos, tests, answer sheets,
The Fire Prevention Program is your company's plan to prevent fires, your plan for evacuation, and how you will deal with fires at your company. This
is OSHA required for all companies with 10 or more employees. However, all companies who want to provide the safest possible workplace should implement
Training includes informing employees of the best safety practices to be used to avoid the fires. For example, employees should be informed of the
company's smoking policy and the fire dangers of smoking. Also, employees should know to avoid using extension cords as a means of permanent fixed
wiring or other areas such as grounding flammables, etc.
The training materials include 'Trainer's Guide', 'Student Guide', testing materials, answer sheets, certificates and videos. Keep in mind your evacuation
plan and procedures must correspond to any other contingency plans your company may have such as California's 'Business Contingency Plan', or Environmental
Protection Agency (EPA) requirements such as Tier II reporting. Also, your company should incorporate evacuation training, i.e. 'Fire Drills' and fire extinguisher
training (required annually).
Personal Protective Equipment
The Personal Protective Equipment (PPE) Plan. This program is an elaboration of your company's policy as it pertains to the use of PPE by your employees.
The program includes a 'Trainers Guide' and 'Student Guide' as well as testing materials, answer sheets, certificates and videos. This training is
best accomplished immediately following Hazardous Communication (HAZCOM) training.
Areas that are covered specifically in our PPE training are Head, Eye, Hand, Hearing, Respiratory, and Foot Protection. That is specifically when, where,
and how they should be used.
Included in the program are blank hazard assessment forms and sample assessment forms. The PPE standard requires that your company's management complete a
written assessment as to what hazards are present in the workplace and what kind of PPE should be used. Our training program greatly simplifies this
hazard assessment task for management!
Keep in mind that if your hazard assessments identify PPE to be used, then it must be used. It is not up to the employee! If Company policy or the
situation dictates usage, then the PPE must be used. PPE for the most part should be provided free of charge to the employee (a possible exception
is steel-toed shoes).
This program is needed only if you have respirators that employees use because the air contamination in the area where they work exceeds an OSHA
Permissible Exposure Limit (PEL shown on the SDS). The written program details the safe procedures your employees must follow while utilizing
respirators. The required OSHA training includes an on-site fit test that insures each employee's personal respirator fits them properly and
maintains a good seal against their face.
Since employees would be required to have a yearly physical (to ensure they can safely wear a respirator), then medical records would have to be
maintained, and employee privacy would have to be assured. Also, you would have to maintain logs ensuring that the cartridges are changed on a
systematic basis. And, of course, you would have to maintain training records, i.e. sign in sheets, tests, signed certificates, etc.
In December 2000, the federal government established a new federal Ergonomic Standard. This was rescinded by the Senate and President Bush in 2001.
California does have an ergonomics standard currently in effect, and it's enforced by CAL-OSHA. The good news is that California employers do not have to implement an ergonomics program unless they have experienced two or more repetitive motion
injuries, in the identical same work activity, in the last twelve months. However, whether they ultimately put a nationwide regulation into effect
or not, you need to be pro-active in preventing these kinds of injuries. Part of being pro-active is ensuring that your employees know the following
concerning Musculoskeletal Disorders (MSDs):
How to recognize common MSDs and their signs and symptoms.
- The importance of reporting MSDs and signs and symptoms, as soon as possible.
- How/who to report MSDs to in the workplace.
- How to recognize risk factors, job and work activities associated with MSD hazards.
These risk factors include:
- Repetition - e.g., repeating same motions every few seconds for 2 hours at a time, or using a device (such as a keyboard and/or mouse) steadily for more than 4 hours daily.
- Force - e.g., lifting more than 75 pounds at any one time, or pushing/pulling with more than 20 pounds of initial force (such as pushing a 65-pound box across a tile floor for more than two hours per day).
- Awkward Postures - e.g., repeatedly raising or working with the hands above the head for more than two hours a day, or working with the back, neck or wrists bent for more than two hours total per day.
- Contact Stress - e.g., using the hand or knee as a hammer more than ten times an hour for more than two hours total per day.
- Vibration - e.g., using tools or equipment that typically have high vibration levels (such as chainsaws, jack hammers, percussive tools) for more than 30 minutes per day or tools with moderate vibration levels (such as jig saws, grinders, etc.) for more than two hours per day.
If you are a member of the printing industry, then it's good to know that PIA/GATF secured a grant from federal OSHA, and they jointly produced
(with OSHA) a voluntary ergonomics program that effectively addresses the pertinent print industry ergonomic issues. You can secure this program
from PIA/GATF directly and conduct your own training, or you can contract with Assured Compliance Solutions, Inc. to use this program in the conduct
of your live employee classes.
Hearing Conservation Program
This program is required if any employee is exposed to noise levels exceeding 85 decibels for a time- weighted-average (TWA) of 8 hours. Should you have
this level of noise exposure, you would have to initiate a Hearing Conservation Program, which would entail training, and hearing tests. Since a hearing
test is in essence a medical record, then you would have to maintain these hearing records ensuring that privacy of the employee is maintained. Also, any
noise level readings taken would also be considered 'exposure records' and, as well would have to be maintained.