2.7.1 General

Everyone who works with or is potentially exposed to hazardous chemicals will receive initial training by the Safety and Health Manager, or someone appointed by the Safety and Health Manager, on the hazard communication Standard and the safe use of those hazardous chemicals. Whenever a new hazard is introduced, additional training will be provided.

The regular safety meetings will be used to review the information presented in the initial training. Foremen and other supervisors will be trained regarding the hazards and the purposes of the various protective measures, in order that they will be available to answer any questions from employees and be able to provide daily monitoring of safe practices.

If there are any questions regarding hazardous chemicals, every employee is to contact his or her immediate supervisor before any contact is made with the chemicals.

Training will emphasize:

• The summary of the Hazard Communication Standard and this written program.
• The chemical and physical properties of each hazardous material (such as flash point, reactivity, etc.), and methods that can be used to protect against the release of or other exposure to chemicals (including chemicals in unlabeled pipes).
• The physical hazards of chemicals (such as potential for fires, explosion, etc.).
• The health standards, including warning signs and symptoms associated with exposure to chemicals, and any medical conditions known to be aggravated by exposure to the chemical.
• All procedures to protect against exposure to hazards (such as personal protective equipment required, proper use and maintenance, work practices or methods to ensure proper use and handling of chemicals, and procedures for emergency response).
• The safe work procedures to be followed by each employee in order to assure protection when cleaning hazardous chemical spills and leaks.
• The locations of the company HAZ-COM manuals, including all SDSs, instruction on reading and interpreting the information on both labels and SDSs, and how employees may obtain additional hazard information.
  

The Safety and Health Manager or his or her designee will review the company’s employee training program and advise on training or retraining needs. Retraining is required only when a hazard changes or when a new hazard is introduced into the work place, but it is the policy of Carter & Carter to provide training on an ongoing basis in the safety and loss control program’s Safety Meetings in order to enhance the effectiveness of the total Program.

As part of the assessment of the training program, the Safety and Health Manager will obtain input from the employees regarding the training that they have received and their suggestions for improving any part of the entire training effort.

The most important aspects of training with respect to chemicals and the HAZ-COM standard are to ensure that Carter & Carter employees:

• Are aware when they are exposed to hazardous chemicals, and of the conditions of such exposure.
• Have the ability to read and use package labels and Safety Data Sheets.
• Follow all appropriate protective measures and company procedures as established.

As part of the ongoing OSHA inspection and enforcement efforts, it can be expected that OSHA Compliance Officers will talk with company employees specifically in order to determine if:

• They have received training with respect to chemicals identification and the Hazard Communication standard;
• They are aware that they are exposed to hazardous chemicals;
• They are aware of the locations in which they can obtain specific information on labels and SDSs.