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It’s been just over one year since Occupational Safety and Health Administration's (OSHA) announced changes to its Hazard Communication (HazCom) Standard that will integrate the United Nations’ Globally Harmonized System of Classification and Labeling of Chemicals (GHS) into OSHA’s HazCom standard. The deadline for compliance training is December 1, 2013. According to the agency’s website, when the original HazCom Standard was implemented in 1983, it gave the workers the ‘right to know,' but the new Globally Harmonized System gives workers the ‘right to understand.'

Both the old and the new standards requires chemical manufacturers and importers to evaluate the chemicals they produce or import and provide hazard information to employers and workers by putting labels on containers and preparing safety data sheets. The old standard allowed employers to put that hazard information on labels and material safety data sheets in whatever format they chose. The new standard requires that information to be presented using the standard GHS which provides a single set of harmonized criteria for classifying chemicals according to various health hazards (e.g., irritation, sensitization and carcinogenicity) and physical hazards (e.g., fire, explosion and corrosion), and specifies model formats and substantive requirements for labels and safety data sheets.

The major changes to HazCom standard are:

• Hazard classification: Chemical manufacturers and importers are required to determine the hazards of the chemicals they produce or import. Hazard classification under the new, updated standard provides specific criteria to address health and physical hazards as well as classification of chemical mixtures.
• Labels: Chemical manufacturers and importers must provide a label that includes a signal word, pictogram, hazard statement, and precautionary statement for each hazard class and category.
• Safety Data Sheets: The new format requires 16 specific sections, ensuring consistency in presentation of important protection information.
• Information and training: To facilitate understanding of the new system, the new standard requires that workers be trained by December 1, 2013 on the new label elements and safety data sheet format, in addition to the current training requirements.

Emergency Film Group’s Global Harmonization & the Hazard Communication Standard DVD training program focuses on OSHA’s changes to the Hazcom Standard. The program includes descriptions of the classifications and subcategories of physical & health hazards of chemicals, information that must be included on a label, signal words, pictograms, hazard statements, the 16 sections of safety data sheets and an instructor's CD-Rom. To learn more, read here. . .

OSHA has introduced several new hazardous material symbols as part of their revised HazCom Act.

by Gordon Massingham, President, Emergency Film Group

 "I want something that will satisfy OSHA's requirements. I want to be able to show them the tape, have them take a test, and they will be certified."

It's the kind of request we get all too often here at Emergency Film Group. When we tell these callers that we don't have anything like that, and that neither does anyone else, some callers hang up in disgust. Maybe they go on calling other companies like ours. Maybe some disreputable salesperson from another company sells the caller a video-based program. Maybe the caller is pleased that he now has found "compliance-only training." Or, at least pleased until OSHA comes to call.

Here is a fact- THERE IS NO VIDEO-BASED PROGRAM THAT WILL CERTIFY YOUR EMERGENCY RESPONDERS!

OSHA's standards for general industry, 29 CFR 1910 Subpart L, 1910.120, and 1910.156 which cover fire brigades and response to hazardous materials emergencies are very clear about training requirements.

The employer must provide training, "commensurate with those duties and functions that fire brigade members are expected to perform." Further, the employer must assure that each member of the fire brigade is able to perform "assigned duties and functions satisfactorily and in a safe manner so as not to endanger the fire brigade members or other employees." Finally, the employers must inform the fire brigade members of any special hazards that exist and develop "written procedures that describe the actions to be taken in situations involving the special hazards and shall include these in the training and education program."

So unless you have a training video that is custom designed and site specific, no video is going to train your plant emergency response team to OSHA's requirements. Even then it is doubtful that the video alone can provide the training.

When you talk about emergency response you are talking about matters, potentially of life and death. No video is going to train a fire fighter to operate a pump, don chemical protective clothing, or proportion foam. Training an emergency responder requires an instructor- someone competent and experienced. It usually requires some classroom work, and some hands-on training in the field- at least some of which should be under simulated emergency conditions. In other words, if you expect an emergency responder to carry out a task, you better be sure that the emergency responder had competency-based training and you better keep records.

Does that mean there is no role for video? We hope there is. But at the Emergency Film Group, we design our videos and the books that accompany them as training aids for the instructor. First, we provide some compelling visuals that otherwise wouldn't be available to the instructor. Secondly, through extensive research and by constant review by leading professionals in the field, we provide eight or ten of the most important lessons to be learned about the subject- with emphasis on safety and good management. So the video might be used as an introduction to the subject, or as a review. But showing the video, no matter how good it is, and doing nothing else, will not put you in compliance.

We can't provide all your training for you, but as our motto says, we can provide "training tools for an increasingly complex and dangerous job."

Gordon Massingham has produced most of the training programs in the Emergency Film Group catalog and has been responsible for creating more than 150 emergency response training programs during the past 25 years. In 2004 he was awarded a Lifetime Achievement Award from the International Association of Fire Fighters.

Note: Although we can’t satisfy all your OSHA training requirements, Emergency Film Group has dozens of video-based training programs that are designed to the latest OSHA and NFPA standards

Hazcom - the Hazard Communication Standard, often called Right to Know - was implemented by OSHA to ensure that employees who work with chemicals are trained in their safe handling and use, to recognize symptoms of adverse health effects related to exposure, and to take appropriate measures in an emergency.

The 2012 update to Hazcom takes a new approach to communicating information in order to ally it with the international initiative known as Globally Harmonized System of Classification and Labeling of Chemicals (GHS), and is now being tagged Right to Understand. Changes include specific criteria in the way physical and health hazards are classified, new requirements for labels, and a new format for Safety Data Sheets, formerly called Material Safety Data Sheets. Ultimately GHS will affect other OSHA standards, and those of other standards-making organizations.

Emergency Film Group's newest program - Global Harmonization & the Hazard Communication Standard - examines the changes to Hazcom. It is appropriate for training personnel who work with or around hazardous chemicals, and also for hazmat teams, firefighters and others who may respond to an incident where chemicals are involved.

For more information about this program, go to the website at https://www.efilmgroup.com/product.php/166.htm.