Hazard Communication Training Online (OSHA and Cal/OSHA)
Short answer.
Employers must give workers effective information and training on the hazardous chemicals in their work area at the time of initial assignment, and again whenever a new chemical hazard the workers have not been trained on is introduced (29 CFR 1910.1200(h)(1)). Construction work follows the same text through 29 CFR 1926.59, and California employers follow 8 CCR 5194. An online course can teach the general content: labels, safety data sheets, chemical hazards and protective measures. The employer must still cover its own written program, chemical list, labeling system and safety data sheet locations. OSHA also says handing out data sheets is not training and that training should let workers ask questions. (OSHA letter of interpretation, October 24, 2005)
Which course do I need?
M Squared sells one Hazard Communication (GHS) course. Its product page lists the rules it covers as 29 CFR 1910.1200(h), 29 CFR 1926.59 and 8 CCR 5194(h), and says it is written at the Authorized User level. It is not split into separate federal and California versions, and it is available in English and Spanish.
| Your situation | Rule | English | Spanish |
|---|---|---|---|
| General industry employer under federal OSHA | 29 CFR 1910.1200 | Hazard Communication (GHS) Online Training | Comunicación de peligros (GHS): capacitación en línea |
| Construction employer under federal OSHA | 29 CFR 1926.59 | ||
| California employer | 8 CCR 5194 |
To compare other courses, see the Federal OSHA online courses, the Cal/OSHA online courses and the Cursos en línea en español, or go to the M Squared Training Academy hub. For a short crew meeting on the same subject there is a Hazard Communication Toolbox Talk, which does not replace the required training. State plans can add their own rules, so check the OSHA training requirements by state page.
What the standard requires you to train on
Under the federal text, employees must be informed of the requirements of the section, of any operations in their work area where hazardous chemicals are present, and of the location and availability of the written hazard communication program, the list of hazardous chemicals and the safety data sheets (1910.1200(h)(2)). Training must include at least:
- Methods and observations used to detect the presence or release of a hazardous chemical, such as monitoring, visual appearance or odor (h)(3)(i).
- The physical, health, simple asphyxiation, combustible dust and pyrophoric gas hazards, and hazards not otherwise classified, of the chemicals in the work area (h)(3)(ii).
- The measures employees can take to protect themselves, including the employer's work practices, emergency procedures and personal protective equipment (h)(3)(iii).
- The details of the employer's program, including an explanation of the labels on shipped containers, the workplace labeling system, and the safety data sheet, including the order of information and how to obtain and use it (h)(3)(iv).
The standard says information and training may be designed to cover categories of hazards, such as flammability, or specific chemicals, and that chemical-specific information must always be available through labels and safety data sheets (1910.1200(h)(1)).
Labels and safety data sheets
A label on a shipped container carries six elements: product identifier, signal word, hazard statement(s), pictogram(s), precautionary statement(s), and the name, U.S. address and U.S. telephone number of the manufacturer, importer or other responsible party (1910.1200(f)(1)). In the workplace, each container of hazardous chemicals must carry either that information or the product identifier plus words, pictures or symbols that give general hazard information, which together with other information available to employees gives the specific physical and health hazards (1910.1200(f)(6)). For a closer look at the pictograms, read GHS pictograms on the job site.
A safety data sheet has 16 numbered sections, from Identification (section 1) to Other information (section 16) (1910.1200(g)(2)). Employers must keep a copy for each hazardous chemical and make it readily accessible during each work shift in the employee's work area. Electronic access is allowed if it creates no barrier to immediate access (1910.1200(g)(8)).
What the employer still has to do
Finishing a course does not complete the employer's duties. The employer must develop, implement and maintain a written hazard communication program at each workplace. It must describe how the label, safety data sheet and training requirements will be met, and it must include a list of the hazardous chemicals known to be present and the methods for informing employees of the hazards of non-routine tasks (1910.1200(e)(1)). Where employees of other employers may be exposed, the program must also cover how those employers get access to safety data sheets (1910.1200(e)(2)). The employer's own chemicals, labels and safety data sheet locations are the part no general course can supply.
California differences
8 CCR 5194(h) follows the same structure and adds two items the federal text does not carry in the same words. Employers must inform employees of their right to receive information on the hazardous chemicals they may be exposed to, the right of their physician or collective bargaining agent to receive it, and the right against discharge or other discrimination for exercising those rights (5194(h)(2)(G)). When a new or revised safety data sheet arrives showing significantly increased risks or new protective measures, the employer must give that information to employees within 30 days of receipt (5194(h)(3)).
Questions you may have
Who has to be trained, and when?
Employers must provide effective information and training on hazardous chemicals in the employees' work area at the time of initial assignment, and whenever a new chemical hazard the employees have not previously been trained about is introduced into the work area (29 CFR 1910.1200(h)(1)). California's text is similar and also requires training at initial assignment and when a new chemical hazard is introduced (8 CCR 5194(h)(1)).
Does online hazard communication training count?
It can count as part of the training. In a 2005 letter, OSHA said the training can be delivered in many ways, naming audio visual, classroom instruction and interactive video, and that it should include an opportunity for employees to ask questions. The letter does not address computer-based courses by name. (OSHA letter, October 24, 2005) The employer must still cover its own program details under (h)(3)(iv). Our course page says the same: it does not replace the training your employer must give on your own job.
Is handing out safety data sheets enough?
No. OSHA's 2005 letter says the training requirements are "not satisfied by merely providing employees with copies of MSDSs." (OSHA letter, October 24, 2005)
Does the standard apply on construction sites?
Yes. The note to 29 CFR 1926.59 says the requirements applicable to construction work are identical to those in 29 CFR 1910.1200.
Can training be given in Spanish?
Yes, and where workers do not comprehend verbal English, OSHA has said the employer must inform and train them in a language that is comprehensible (OSHA letter, April 10, 1988). Our course has a Spanish version: Comunicación de peligros (GHS): capacitación en línea.
What do I receive when I finish?
Per the course page, you take a final exam and receive a certificate of completion from M Squared Safety Solutions, Inc. when you pass.
How training works here
You take the course online at your own pace, on a phone or a computer. The course has a final exam. If you have a question about the material, call an M Squared trainer at 949-954-6581, Monday to Friday, 8 AM to 5 PM Pacific time.
The limit: this course does not replace the training your employer must give on your own job, including your written program, chemical list, labeling system and safety data sheet locations, and any hands-on practice.