From: Allen Niemi <anniemi**At_Symbol_Here**MTU.EDU>
Subject: Re: [DCHAS-L] question on Hazcom training
Date: Wed, 13 Jan 2016 09:59:26 -0500
Reply-To: DCHAS-L <DCHAS-L**At_Symbol_Here**MED.CORNELL.EDU>
Message-ID: CAN0bzO5EkQrnbdN4BQMFQF=SaXag-5JTN==pc1AAdKmTVywOmw**At_Symbol_Here**

Dave, I think you are way overinterpreting (I'm not even sure your state would recognize that interpretation if you have a state plan.). For one thing, the interpretation you are citing says that the substance must be a consumer product -- not just similar to one -- and must be used in the same way and with the same degree of exposure as a consumer. Consumers do not have the same cleaning exposure as a custodian does -- only obsessive people clean all day. If the substance meets the OSHA definition of a hazardous substance and there is a potential for exposure (What happens if the dispenser malfunctions or there is a spill?) then you are on the hook to provide training to those who are exposed. So, in my opinion, your janitors need to be trained in the full GHS/SDS hazcom rules and your written plan.


On Tue, Jan 12, 2016 at 5:08 PM, David Roberts <chemprof622**At_Symbol_Here**> wrote:
Thanks for the replies. We have a lot in our chemical storeroom - but I am the only one in contact with those. I undergo GHS/HazCom training, but I don't know how necessary it is for others to do the same. Our janitors use RTD systems to dispense the cleaning solutions they use. My reading of the rules is something to the effect of: any chemicals used in the same way that a consumer would use them are not considered hazardous and therefore are not subject to the rules. you don't have to have SDS's for them, nor do you have to include them in your HazCom procedures. Am I over interpreting this, can I simply not worry about simple cleaning solutions for our 3rd shift in terms of GHS training and such? I'm just trying to see what others do here - I'm willing to do whatever, I just want to know if I'm being too extreme, in either direction.

Our 3rd shift personal are not allowed in to our chemical storeroom - so it literally is just me. I'm the person listed on all plans in the event of a major release, etc-, and we do have others on campus trained in the event that I'm not around. So I'm not worried about the few on campus that need training for obvious reasons.

I'm just trying to determine how deep I need to go with GHS/SDS training. If our janitorial staff are simply using things right out of the bottle, and those things are no different than typical household consumer products - do I need to train them on it? If so, I will, but if I don't have to and if it's really not a bad thing then I=E2=80™m not going to worry.

With that said - I will ensure that everybody is familiar with what they do - I'm just trying to write down or procedures and rules for the one time we do have an inspection or whatever. I am not trying to make an uncomfortable work space, I'll make sure everybody is ok with what they are doing - I'm just trying to keep it simple ;)



> On Jan 12, 2016, at 4:46 PM, Wilhelm, Monique <mwilhelm**At_Symbol_Here**UMFLINT.EDU> wrote:
> Hi Dave,
> I am in a completely different situation from you as we have a lot of chemicals in my Chemistry Department. Our CHP requires refresher every 3 years. My faculty actually do it annually as it is easy online training with a quick review proficiency with me. But, my husband used to be a manager for a pet supply chain and he had to provide HazCom training to all of his employees that came into contact with cleaning supplies or the fish maintenance supplies.
> Good luck,
> Monique Wilhelm
> Laboratory Manager
> Department of Chemistry & Biochemistry
> University of Michigan - Flint
> -----Original Message-----
> From: DCHAS-L Discussion List [mailto:dchas-l**At_Symbol_Here**] On Behalf Of David Roberts
> Sent: Tuesday, January 12, 2016 12:50 PM
> To: DCHAS-L**At_Symbol_Here**MED.CORNELL.EDU
> Subject: [DCHAS-L] question on Hazcom training
> Hello world,
> I have what I feel is a simple question on hazcom training. Let's try not to take this to the worlds edge here, but instead just focus on what is in fact necessary and needed here. I'm at a small (2000 student) Liberal Arts college. I have a Ph.D. in chemistry, and have been managing our chemical storage for the past 18+ years. I'm a state certified hazmat technician (with our local and state fire responders). With that, I've had a lot of training in the area of hazardous waste, waste management, osha certs, epa audits, nfpa, etc-
> But, I am uncertain of what to do here. At what level do most people go to with training of GHS and the hazard communication plan. Is it just the concept of where do we store MSDS's (that are basically just cleaning supplies), what labels are put on our cleaning chemicals, etc-??? Outside of academics, we really do not have a load of chemicals (really, I promise). Our cleaners that we have adopted are all green certified (whatever that means), and so there really isn=E2=80™t a whole lot here. Is it necessary to train all of our facilities people on the hazcom standard, or can we simply make sure all the supervisors know and leave it at that. What is the rule here? I do understand the "right to understand" concept and ensuring that all employees need to know what they have and what they are working with.. But frankly, the majority do not ever see a chemical and harsher than windex while working here.
> So we do have grounds people, and they are working with fertilizers/pesticides. Most of them have outside certifications that allow them to apply things, so they have training above and beyond. For them, I see maybe going over this information. We have a few others that also may apply. I guess I'm just trying to see if people get third shift and janitors to go through this training and how necessary that is. I am more than willing to do that, there is no fight on that, but if I can minimize how many people I have to torment with these trainings, that would be nice.
> I'm just wondering what others do. I can do an online thing that is simple, maybe a part of employee orientation, but what is the frequency of the refreshers?
> I understand that part of the hazard communication plan is to define training, so I guess that's what I'm asking here. How do most define it, and what do they actually do?
> Thanks.
> Dave

Allen Niemi, PhD
Occupational Safety and Health Services
Room 322 Lakeshore Center
Michigan Technological University
Phone: 906-487-2118
Fax: 906-487-3048

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