XIII. TRAINING A multitude of training requirements are addressed by OSHA and other safety, health and environmental regulations. A summary of these requirements are presented. A. Hazard Communication/Right-to-Know Training The Oklahoma Department of Labor has adopted the OSHA Hazard Communication Standard (also known as the Right-to-Know Law) applicable to state employees. The basis of the Hazard Communication Standard is that employees have a right and need to know the properties and potential safety and health hazards of substances present in the workplace to which they may be exposed; and that such knowledge is essential to reducing the incidence and cost of occupational illness and injury. Under this standard, and under OU policy, all OU employees must receive information and training on the OU Hazard Communication Policy and Program beginning with the employee's initial assignment and when new tasks or chemicals are introduced. Refresher training must be provided at least annually. Employers must tell all employees, including contract, temporary, and student employees that the hazard communication standard exists, and inform them of the mandatory information and the training program. Employees must be provided with an explanation of chemical hazard labeling systems, how to use SDSs, and how hazard information can be obtained. Employees must also be instructed in how to handle unsafe conditions or practices and communicate safety concerns to the appropriate individuals. Employers must document performance, content and attendance of the training program. Hazard Communication training is provided in the General Safety/Hazard Communication training course on-line at the EHSO website at http://www.ou.edu/ehso/training.html. Sources: OU Hazard Communication Policy and Program B. Laboratory Safety/Chemical Hygiene Training Under the OSHA and Oklahoma Department of Labor regulations entitled "Occupational Exposure to Hazardous Chemicals in Laboratories", laboratory employees must be provided with information and training to ensure that they are apprised of the hazards of chemicals present in their work area. In this training, employees shall be informed of: 1. the contents of the OSHA standard and its appendices, a copy of which shall be made available to the employee, 2. the location and availability of the laboratory's Chemical Hygiene Plan, 3. the permissible exposure limits for OSHA regulated substances or recommended exposure limits for other hazardous chemicals where there is no applicable OSHA standard, XIII-1
4. signs and symptoms associated with exposures to hazardous chemicals used in the laboratory, 5. the location and availability of known reference material on the hazards, safe handling, storage, and disposal of hazardous chemicals found in the laboratory including, but not limited to, MSDSs received from the chemical supplier, 6. methods and observations that may be used to detect the presence or release of hazardous chemicals (such as monitoring conducted by the employer, continuous monitoring devices, visual appearance of odor of hazardous chemicals when being released, etc.), 7. the physical and health hazards of chemicals in the work area, and 8. the measures employees can take to protect themselves from these hazards, including specific procedures to 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. Laboratory safety training is available on-line at the EHSO website at http://www.ou.edu/ehso/training.html. Source: OSHA Occupational Exposure to Hazardous Chemicals in Laboratories Standard (29 CFR 1910.1450) C. Bloodborne Pathogen Training OSHA and the Oklahoma Department of Labor require employees with occupational exposure to blood or other potentially infectious material (including working with human cell lines and human cell strains) to receive bloodborne pathogen training at the time of assignment to tasks where occupational exposure may take place and at least annually thereafter. Additional training must be provided and documented when changes affect employees' occupational exposure. This training must be documented. The minimum training program must include: 1. a copy of the regulatory text, 2. a general explanation of epidemiology of and symptoms of bloodborne diseases, 3. modes of transmission of bloodborne pathogens, 4. an explanation of the Exposure Control Plan and how to get a copy of plan, 5. appropriate methods for recognizing tasks and other activities that may involve exposure to blood and other potentially infectious materials, XIII-2
6. use and limitations of engineering controls, work practices, and PPE, 7. selection of PPE, 8. information of hepatitis B vaccine, including efficacy, safety, etc., 9. appropriate actions in emergencies with blood or other potentially infectious materials, 10. the procedure to follow if an exposure incident occurs, 11. post-exposure evaluation information, 12. signs and labels required, and 13. questions and answer with instructor. Bloodborne pathogen training is available on-line at the EHSO website at http://www.ou.edu/ehso/training.html. Sources: OSHA Bloodborne Pathogens Standard (29 CFR 1910.1030) OU Exposure Control Plan D. Biological Safety Training The Centers for Disease Control and Prevention (CDC) and the National Institutes of Health (NIH) have training requirements for persons working with microorganisms, viruses, infectious agents or potentially infected materials. These agencies require that personnel must be aware of potential hazards, and must be trained and proficient in the practices and techniques required to handle such material safely. The director or person in charge of the laboratory is responsible for providing or arranging the appropriate training of personnel. Specific CDC and/or NIH requirements for training are as follows: 1. Each laboratory should develop or adopt a biosafety or operations manual that identifies the hazards that will or may be encountered, and that specifies practices and procedures designed to minimize or eliminate exposures to these hazards. Personnel should be advised of special hazards and should be required to read and follow the required practices and procedures. 2. For all levels of biological safety (BSL1 - BSL4), instructions to employees should include training in aseptic techniques and in the biology of the organisms used in the experiments so that the potential biohazards can be understood and appreciated. The Principal Investigator/laboratory supervisor should ensure that everyone in the laboratory is familiar with both the potential hazards of the work and the emergency plan. 3. For BSL1 work, laboratory personnel should have specific training in the procedures conducted in the laboratory. XIII-3
4. For BSL2 work, laboratory and support personnel should have specific training in handling pathogenic agents including the potential hazards associated with the work involved, the necessary precautions to prevent exposures, and the exposure evaluation procedures. Personnel should receive annual updates or additional training as necessary for procedural or policy changes. 5. For BSL3 work, laboratory and support personnel should have specific training in handling pathogenic and potentially lethal agents including the potential hazards associated with the work involved, the necessary precautions to prevent exposures, and the exposure evaluation procedures. Personnel should receive annual updates or additional training as necessary for procedural changes. In addition, the laboratory director is responsible for ensuring that, before working with organisms at Biosafety Level 3, personnel demonstrate proficiency in standard microbiological practices and techniques, and in the practices and operations specific to the laboratory facility. This might include prior experience in handling human pathogens or cell cultures, or a specific training program provided by the laboratory director or other competent scientist proficient in safe microbiological practices and techniques. 6. For BSL2 animal work, animal care laboratory and support personnel should receive appropriate training on the potential hazards associated with the work involved, the necessary precautions to prevent exposures, and the exposure evaluation procedures. Personnel should receive annual updates, or additional training as necessary for procedural or policy changes. The OU Institutional Biosafety Committee has developed online training for General Biosafety at https://www.ouhsc.edu/ehso/training-norman/new_logon.asp. The PI or person in charge of the laboratory is responsible for providing organism or toxic-specific training of personnel. Sources: CDC/NIH Biosafety in Microbiological and Biomedical Laboratories, U.S. Department of Health and Human Services Public Health Services, Centers for Disease Control and Prevention and National Institutes of Health, HHS Publication No. (CDC) 93-8395, 4 th Edition, May, 1999, and 5 th Edition, Feb., 2007. NIH Guidelines for Research Involving Recombinant or Synthetic Nucleic Acid Molecules, March 2013. E. First Aid/CPR Training All laboratories are encouraged to have one or more persons on staff who have had formal first aid and/or CPR training. Such training involves learning methods to stop bleeding, artificial respiration, and prevention of shock. In addition, employees should be trained on how to access outside emergency resources. F. Fire Extinguisher Training Training of employees in the use of fire extinguishers is required by OSHA 29 CFR 1910.157 (g) "where the employer has provided portable fire extinguisher for employee XIII-4
use in the workplace." Such training should be conducted at initial employment and annually thereafter. Source: OSHA Portable Fire Extinguisher Standard (29 CFR 1910.157) G. Spill Response Training All employees should be trained in the proper methods for spill response. See Section XII., "Spill Procedures/Emergency Response" for additional information. H. Respiratory Protection Training Respirators may be required in certain circumstances to protect the health of the employee. If respirators are worn, the employee must be trained, be fit-tested to ensure the proper fit, and be medically evaluated. The training includes: 1. use of respiratory protection by employees in accordance with instructions and training received from the employer, 2. how to select appropriate respirators, and 3. written procedures governing respirator use during normal or emergency operations. I. Department of Transportation/International Air Transport Association Shipping Training 1. United States Department of Transportation (DOT) DOT regulates the transport of hazardous materials to, from or through the United States. DOT regulations are found in part 49 of the Code of Federal Regulations (49 CFR), are enforceable by law, and can carry significant fines and other penalties for failure to comply. These regulations and requirements apply to anyone who, with respect to dangerous goods or hazardous materials: a. transports; b. determines the hazard class of a hazardous material; c. selects hazardous materials packaging; d. fills a hazardous materials packaging; e. secures a closure on a filled or partially filled hazardous materials package; f. marks a package to indicate that it contains a hazardous material; XIII-5
g. labels a package to indicate that it contains a hazardous material; h. prepares a shipping paper; i. provides and maintains emergency response information; j. reviews a shipping paper to verify compliance with the Hazardous Materials Regulations or international equivalents; and/or k. manufactures and/or tests packaging materials for dangerous goods use. 2. International Air Transport Association (IATA) The IATA Dangerous Goods Regulation (DGR) is the industry standard for transporting dangerous goods by air. While IATA is not a federal or international regulatory agency, in general, unless the IATA DGR is followed for the air transport of dangerous goods, air carriers will not accept the shipment. IATA does not apply to packages that are shipped exclusively by ground transportation. 3. Training Requirements a. Both DOT and IATA have specific training requirements for persons who package and ship certain hazardous materials. Among these hazardous materials are infectious (etiologic) agents, diagnostic specimens, formaldehyde solutions, and carbon dioxide. (1) DOT requires initial training for hazmat employees who prepare packages for shipment which includes general awareness/familiarization, function-specific, and safety training. In addition, Security Awareness Training is mandatory which provides an awareness of security risks associated with hazardous materials transportation, methods designed to enhance transportation security and how to recognize and respond to possible security threats. Recurrent training is required every three years. (2) IATA requires similar training, but recurrent training is required every two years. b. Meeting the Training Requirements (1) The EHSO provides an on-line course at (http://www.ou.edu/ehso/training.html) which meets the DOT/IATA general awareness and function-specific training requirement for shipping infectious substances, diagnostic specimens, dry ice, and formaldehyde solutions XIII-6
only. Should additional types of materials need to be shipped, contact your campus EHSO. (2) Safety training requirements are to be met by having current Hazard Communication training, current Bloodborne Pathogen training for human specimens such as human blood or human tissue, and/or Laboratory Safety training for non-clinical infectious substances. (3) Security Awareness Training is accomplished by completing a separate training module using a CD-ROM program provided by DOT. Contact the Oklahoma City EHSO to receive a copy of this free CD-ROM. This separate, but required, training module has a final test which should be completed, printed, and attached to the certificate received upon completion of the self-study or on-line EHSO shipping training course. Sources: DOT Hazardous Materials Regulations (49 CFR Parts 171-172) IATA Dangerous Goods Regulations XIII-7