MSDS Sheets: Is it acceptable to distribute copies of MSDSs and consider that to be training?
OSHA's Hazard Communication standard (HCS) contains the required, minimum elements in an employee information and training program. See, 29 CFR 1910.1200(h). Employers must provide training on hazardous chemicals in an employee's work area when the employee receives his/her initial work assignment and whenever a new physical or health hazard is introduced into the employee's work area. The HCS training requirements are not satisfied by merely providing employees with copies of MSDSs.
Appendix A of the Compliance Directive for Hazard Communication, CPL 2-2.38D explicitly provides that "[t]he training provisions of the HCS are not satisfied solely by giving employees the [material safety] data sheets to read. An employer's training program is to be a forum for explaining to employees, not only the hazards of the chemicals in their work area, but also how to use the information generated in the hazard communication program. This can be accomplished in many ways (audio visual, classroom instruction, interactive video), and should include an opportunity for employees to ask questions to ensure that they understand the information presented to them."
The HCS directive, which is available on OSHA's website at www.osha.gov, also provides additional information concerning an employer's obligation to provide employee training under the HCS. Other useful information pertaining to the Hazard Communication standard can be found at: www.osha.gov,