Fewer than 20 words. In the 320-plus-page rulemaking on Globally Harmonized System of Classification and Labeling of Chemicals (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.
How Much Training Is Enough?
The regulation doesn't address training to different levels of responsibility. GHS is not like confined space training, for example, where the level of training relates to the job duties. Common sense tells you that the manager who implements the company hazcom program needs a different level of training that the receptionist who signs for packages, but the regulation is silent on levels of training.
Then there’s “that guy.” Every class seems to have one, that guy who knows just enough about the subject to play “stump the instructor.” That is not to say that the questions aren’t interesting or that they don't add to the learning experience, but the instructor who has prepared to teach a general awareness-level class is in for a long class when “that guy” starts asking Ph.D.-level questions. We find that we need to arm our instructors with more information than they will ever teach just in case some students want to “dive deep” on the material. In the case of GHS, a very simple labeling system hides what turns out to be some very complex and subtle changes in the way we classify chemicals. Just a few questions from “that guy” can derail a basic class on GHS very quickly.
The Volunteer Fireman
And that gets us to the heart of the challenge in teaching GHS. A simple class (this is the new label, these are the pictograms and this is the SDS) doesn’t begin to address the changes for someone involved in response. In teaching workers in industrial settings, we frequently have students who have hazardous response training or are volunteer firemen in their off time. They are used to the National Fire Protection Association (NFPA) 704 “fire diamond” that you see on the side of a warehouse. It classifies chemicals on a 0-4 scale. Zero means there is no chemical hazard. Four means a severe hazard. GHS turns that upside down. A category 1 chemical is the most hazardous. Category 4 is the least. If you have spent your career reading NFPA 704 signs, this drives you nuts.
So we had to add a section that explains the difference. NFPA signs are aimed at response situations where you don’t know what is in the burning building, but your binoculars tell you not to go any closer. GHS categories are a way for manufacturers to start defining the hazards of a chemical, but by the time it reaches the average worker, the category number is irrelevant because the critical information is contained on the label and SDS. Ninety percent of students don’t even need to hear that information, but when that 10 percent starts asking questions, the instructor needs to be able to explain it.
All of that drove the development of our GHS training. That’s right – just a handful of words in a regulation caused us to choose classroom training over computer-based modules, create a course that could be expanded or contracted to meet the knowledge the student brings to the class and, ultimately provide instructors with more information than they may need to teach the course ... just in case.
Ken Wells is the director of special projects at PECsafety.com. PEC is a leader in both safety training and vendor safety pre-qualification, specializing in the oil and gas industry. Wells has more than 20 years of experience in safety management, training and regulatory compliance. He can be reached at [email protected].