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GHS Training Deadline

—It’s coming… Will YOU be prepared?

It is incredible to me to find that, in the middle of November 2013, most companies and organizations are not prepared for the GHS Training Deadline.  I mean, OSHA has only been promoting this change for around 2 years now.  What’s the holdup?  I have personally received over 30 emails with messages such as this:

OSHA’s updated Hazard Communication Standard provides a common and coherent approach to classifying chemicals and communicating hazard information on labels and safety data sheets. The first deadline in the implementation phase is Dec. 1, 2013, the date by which employers must train workers on the new label elements and the safety data sheet.

GHS is here and the process of complying is upon us!  Why is this such a shock?  We have all had 2 years to prepare and take care of the training. Yet it seems that most are ill-prepared to meet this deadline and, I am sure, are banking on the grace period OSHA will offer up.

This is really an issue of effective hazard communication for our employees, so in my opinion, there is no excuse for not being prepared.  The new measures are being put in place to provide better safety information to workers in order to minimize fatalities, injuries, and illnesses in the workplace —protecting employees and saving everyone’s time and money!

The process is not that difficult to follow. Simply make sure employees are educated in the following:

  •  New Pictograms
  •  SDS (New Safety Data Sheet Format)
  •  New Label Format and Requirements
  •  Completely Cover Chemical Hazards in the Workplace

The second phase deadline is in 2015, so we again have a couple of years to be ready for the changes.  Let’s take this one seriously!



Is a 40 hour HAZWOPER online class in California, considered good enough training?

—Can an Online Course Cut it?

Many times a month I am asked, “Is it good enough training to take a 40 hour HAZWOPER course online in California?”  Well, my answer is really simple: what do the regulations say?  When you look them up in 8 CCR 5192, you will find that specific training on equipment and respiratory protection, as well as suit donning and doffing, are required. How is it possible to teach an employee to use specific equipment online and have that training considered sufficient?  Companies are always looking to save money—a pretty understandable concept—however in this case, it is to the detriment of their employees!  Let’s think about this: how can an employee be adequately trained with the equipment they will utilize if they’ve only ever read about it?

I hear that many companies state in response to this that they will do the training “in-house.”  In that case, I would ask these questions:

  • Where did their trainers gain the ability to instruct students about technical equipment?
  • What makes them experts on the equipment?
  • What formal training do the instructors have?

In most cases, the answer to all of these questions is, not much at all!  I know this because I spent 28 years in the Hazardous Materials Emergency Response field.  In that time, I have come to understand that most instructors in this field are lacking in much actual, on-the-job experience.  They know very little about what really takes place with response personnel and equipment in real-live situations.

Yes, I will say this over and over, as I know this to be the case: people like to run around with certificates and claim to be experts!  This scares me to no end.   I once attended a training session led by an instructor who got up and dazzled the class with all this experience and background he said he had… until I started to ask a few technical questions that any person with a couple of years in this field would be able to answer.  As I expected, I got the traditional three-step-dodge.  It was only after the class, when I asked this individual to tell me when and where he was in the field doing this type of work, that he finally admitted that he just had his Instructors’ Certificate and no real experience— what a surprise!  Sadly, this tends to be the case more times than not.

Let’s get back to the topic at hand: you should have a live instructor with professional experience conducting training courses.  While many may disagree with me in these strict requirements, I would say I have a solid understanding of the subject as one who has had first-hand experience responding to many incidents. My answer has always been this simple and straightforward.   Adequate HAZWOPER training should be conducted in person by an instructor with formal background in this field, technical training such as from a manufacturer, and real response experience.