Training Requirements: Chemical Awareness & Emergency Response (Part 2 of 4)

While the first article in this four-part series on training provided an overview of RMP/PSM/CalARP training requirements, we will now take a closer look at the required training for general facility employees. While it may seem like only employees who operate a hazardous chemical process need training, it is not true. General employees at your facility need to be trained on (1) chemical safety and health hazards and (2) emergency response. This includes forklift drivers, office staff, and even upper management. This training should be included in the new employee orientation or onboarding process. While it is not a prescriptive requirement, regulatory agencies often expect and enforce annual refresher training. Because these training topics are connected, many facilities combine them into a single training.

Employees need to be trained on the hazards of the chemical. This is similar to HazCom training that you may already be implementing for other chemicals. Considering the extremely hazardous nature of the chemical that requires you to comply with RMP/PSM, we recommend emphasizing such items as:

• Physical Attributes: what does it look like or smell like?
• Chemical Qualities: will it vaporize to atmosphere or pool around the ground?
• Health Effects: what will exposure do to your skin, eyes, or breathing?
• First-Aid: what should you do if you are exposed?
• Exposure Limits: what concentration of the chemical is safe work in (if at all)?

This is an extremely easy training to administer and all of this information will be listed on the chemical’s SDS (Safety Data Sheet). All employees should also be trained on emergency response. Some facilities may plan to take offensive measures to stop releases, but this is rare. Most facilities opt to be “non-response” which means they rely on the local fire department or equivalent agency to assist in emergency operations. This article will only cover training for the latter scenario. We recommend the following topics be covered as part of your emergency response training for all facility employees:

• Reporting Leaks: notify a supervisor or other appropriate person.
• Alarms: how will employees and visitors know if there has been a release?
• Evacuation Procedures: where are the staging areas and how should windsocks be used?
• Employee Accounting: employees should wait to be counted instead of leaving the premises.
• Non-Response: employees should be told not to attempt performing any emergency repairs or rescue operations if your facility has chosen to be a non-response facility.

All of this information should be included in your Emergency Action Plan/Emergency Response Program. The recommended method for training employees on emergency response is an annual evacuation drill combined with tailgate safety meetings as necessary.

Anyone equipped with their Emergency Action Plan/Emergency Response Program and the chemical SDS is qualified to perform this training. Often this content can be covered in a quick tailgate safety meeting. This information should be included in your new hire paperwork to ensure employees are trained initially. If your company has any type of season where additional employees are hired, we recommend you perform your annual training at this time. This will ensure all new employees receive the training initially and that all other employees receive the refresher training. For general employees, this is the only compliance requirement associated with the RMP/PSM/CalARP training element. Read Part 3 and Part 4.