(11) Training Requirements
11.1 - OSHA Requirement
The employer shall provide employees with . . . training to ensure that they are appraised of the hazards of chemicals present in their work area. Such information shall be provided at the time of an employee's initial assignment to a work area where hazardous chemicals are present and prior to assignments involving new exposure situations. The frequency of refresher information and training shall be determined by the employer.
[Training shall include:]
a. Methods and observations that may be used to detect the presence or release of a hazardous chemical (such as monitoring conducted by the employer, continuous monitoring devices, visual appearance or odor of hazardous chemicals when being released, etc.).
b. Physical and health hazards of chemicals in the work area.
c. Measures employees can take to protect themselves from these hazards, including specific procedures the employer has implemented to protect employees from exposure to hazardous chemicals, such as appropriate work practices, emergency procedures, and personal protective equipment to be used.
d. Applicable details of the employer's written CHP.
11.2 - Chemistry Department Implementation of the OSHA Requirement [39]
A Department-specific orientation is offered at the beginning of the Fall semester.
Upon joining the Department, every member must attend this safety orientation,
which is conducted by the Environmental Health and Safety Chemical Hygiene Officer.
The attendance requirement applies to faculty, post-doctoral candidates, graduate
and undergraduate students, and office and shop staff. Janitorial staff will
be trained according to University CHP requirements.
Upon request, the EHS CHO will conduct an orientation for individuals who join the Department at a time other than the beginning of the Fall semester. This orientation will take place within 1-2 weeks of the request. The person responsible for making the arrangement is the PI for self or students; Laboratory or Instructional Supervisor for TAs; post-doc for self; or Director of Laboratories for staff. Attendees at one of these specially-scheduled orientations must also attend the fire safety portion of the next earliest departmental Fall orientation.
In its orientation, EHS will cover rights and responsibilities under the OSHA
Standard, and procedures for working with chemicals. The PI must provide lab-specific
safety training.
11.3 - Safety Orientation Organization
a. The CHO, working with members of the Chemistry Department Safety Committee, will develop the contents of the orientation and will arrange the time and location.
b. The CHO will take attendance at the orientation and retain the record. The Department may take punitive action against workers who neglect to attend.
11.4 - Safety Orientation Topics
a. Contents of the applicable OSHA Standard(s), and how the University meets its responsibilities.
b. Availability of the Chemistry Department Chemical Hygiene Plan, MSDSs, and additional resources on all aspects of laboratory health and safety relevant to employee exposure.
c. How to read an MSDS.
d. Physical and health hazards of chemical classes (flammables, reactives, carcinogens, corrosives, etc.) and general procedures for handling, storing, and disposing of these materials.
e. Methods and observations to detect the presence or release of hazardous chemicals.
f. Signs and symptoms of exposure to chemicals and availability of medical consultations and exams.
g. Measures to protect from health hazards - use of fume hoods and personal protective equipment.
h. Protocol for dealing with faulty hoods and equipment and with lack of proper safety equipment.
i. Special operating procedures to be used for extremely hazardous chemicals.
j. How to conduct a hazard evaluation of lab operations.
k. How to conduct a laboratory inspection.
l. OSHA PELs and other recommended limits (by the National Institutes for Occupational Safety and Health, and by ACGIH).
m. First aid and fire safety.
n. Use of emergency equipment.
o. Filing incident report forms.
11.5 - Distribution of Safety Materials
At the beginning of their relationship with the Department, all members will
receive copies of the American Chemical Society Safety in Academic Chemistry
Laboratories and the Department-specific safety supplement.
The following materials will be distributed by the CHO at each Fall safety orientation
session:
a. OSHA Standard fact sheet.
b. List of emergency telephone numbers including that of the CHO.
c. Sample MSDSs and fact sheets on how to read them.
d. Chemical storage scheme chart.
e. List of hazard classes and chemical examples.
f. Hazard review checklist.
g. Waste disposal guideline sheet.
h. Laboratory inspection form.
i. Incident report form.
11.6 - Department Safety Quiz
In order to hold a TA position, or to receive a lab or shop key, a Department
member must pass a safety quiz based on the ACS manual and the Department supplement.
At the time a key is issued, the recipient must sign a voucher, indicating agreement
to read the Chemical Hygiene Plan and to observe its standards.
Records of quiz passes will be kept by the office of the Director of Laboratories.
11.7 - Safety Training Responsibilities of the PI
The PI must ensure that all workers are trained to deal with laboratory hazards.
The training requirement may be satisfied in part by having workers attend either
the EHS Fall safety orientation or another specially scheduled orientation as
described in section 11.2. Additionally, the PI must provide the lab-specific
training specified in the CHP, some points of which are listed here:
a. Location and contents of the OSHA (29 CFR) Laboratory Standard and the departmental CHP.
b. Standard and lab-specific operating procedures.
c. Location of MSDSs and how to read them.
d. Use of hoods and assessment of their function.
e. Emergency equipment and procedures.
f. Emergency phone numbers.
g. Responsible waste disposal.
The PI will arrange special training for his/her workers whenever novel hazards are introduced, or when lab conditions or practices change. Such refresher training will be scheduled or integrated into other lab activities as needed. Assistance may be provided by the CHO.
The PI is responsible for ensuring that all workers receive the EPA training
(see the next section).
11.8 - EPA Hazardous Waste Training
In addition to the above OSHA-mandated training requirements, the EPA has its
own hazardous waste training requirements. Everyone who generates or handles
hazardous waste must receive training in EPA-approved procedures. The initial
training must be updated annually, most conveniently by completing a review
at the EHS website. [40]
References:
[39] Adapted from the Stony Brook University CHP pp 66-74.
[40] Environmental Health and Safety < http://www.ehs.sunysb.edu/waste/certs.asp> accessed May 02.