Back in 2013, employers were advised of the requirement to train employees regarding new label elements and safety data sheets but there have been questions about why some employees would need to be trained. For example, an office employee cleans their desk surface weekly with a cleaning product purchased by the employer from a grocery store and is available for employee use. Is GHS training required for that employee?
The Technical Answer
California Code of Regulations 5194(b)(5)(G) excludes incidental use as follows:
(G) Consumer products packaged for distribution to, and use by, the general public, provided that employee exposure to the product is not significantly greater than the consumer exposure occurring during the principal consumer use of the product; GHS training is required for employees working with hazardous substances on a regular basis in the course and scope of their employment.
The Practical Answer
GHS Training is not required for incidental use of a consumer product used in a consumer manner but general awareness training for all employees of the hazardous material identification system would be considered wise and a ‘best practice’ for all employers. Why? Because in the event of an injury to an employee caused by substances in the workplace, it could be deemed negligent that an employer provided a product but not information of its hazardous nature. Free information and GHS training materials are readily available from many sources, see below.
Still unsure of whether to train? Call OSHA Compliance 916-263-0704. I reached a knowledgeable person on my first try and/or call your insurance agent/broker for information.
California Code of Regulations-Hazard Communication https://www.dir.ca.gov/title8/5194.html
Cal OSHA Safety and Health Fact Sheet on GHS-Globally Harmonized System-DIR http://www.dir.ca.gov/dosh/dosh_publications/ghs_fs.pdf
Guide to the California Hazard Communication Regulation-DIR https://www.dir.ca.gov/dosh/dosh_publications/hazcom.pdf
US Department of Labor –OSHA Hazard Communication https://www.osha.gov/dsg/hazcom/index.html
Free PowerPoint presentation http://www.osha.gov/SLTC/hazardcommunications/ghsoverview.ppt
Free YouTube Training Video https://www.youtube.com/watch?v=PkGbof7FeZA
Sacramento Safety Center http://safetycenter.org/
If you have any questions or comments, please do not hesitate to contact me.
Jackie Sudia-Reno, AIC, ARM, CRIS
Claims and Risk Management Liaison
Warren G. Bender Co.
(916)380-5333 (Direct Phone & Fax)