MSHA HAZCOM TRAINING AND THE Z490.1 STANDARD

This article will focus on the ANSI Z490.1 Standard and the attention that has been placed on the document by the mining industry since it was referenced by the U.S. Mine Safety and Health Administration (MSHA) codified a final regulation in Volume 67 of the Federal Register on June 21, 2002. During the time of this reference the standard was still in draft form, but was in the final stages of ANSI approval. The MSHA regulation is titled:

Hazard Communication (HazCom), Final Rule and Withdrawl of Interim Final Rule (30 CFR Part 42 et al.)

MSHA cited the following reasons for the regulation:

MSHA finalized this regulation since chemicals in the mining industry pose a range of hazards to exposed miners, from mild health effects to death. Some chemicals cause or contribute to chronic health problems, such as heart or kidney disease or cancer. Others cause acute injuries or illnesses such as dermatitis, burns, and poisonings. Some chemicals pose hazards by contributing to fires and explosions. The toll of chemically-related injuries and illnesses in the mining industry can be obscured by years of latency between an exposure to a chemical and the onset of an illness.

MSHA's Hazard Communication Standard, which we have called HazCom, expresses two safety and health principles: miners have a right to know about the chemical hazards where they work and you have a responsibility to know about the chemical hazards at your mine. HazCom requires you to inform miners about chemical hazards1.

1 Hazard Communication (HazCom), Final Rule, Single Source Page

Training is a significant portion of this rule and SH&E professionals have been working hard within the mining industry to implement programs to comply with the rule. Since the finalization of this rule, significant interest has been generated within the mining industry about the American National Standard (ANSI) Z490.1-2001, Criteria for Accepted Practices in Safety, Health, and Environmental Training. This interest was generated due to some language in the discussion portion of the rule (Page 42324) addressing administration of training and compliance assistance. Some of the language from this section generating the interest of SH&E professionals is as follows:

Some commenters to the proposed and interim final rules recommended that MSHA administer the HazVom training because it could result in a higher level of consistency and quality in the training. One commenter to the interim final rule suggested that MSHA cited ANSI Z490.1-2001, "Criteria for Accepted Practices in Safety, Health, and Environmental Training", in the final rule for you to follow.

…We encourage you to use the ANSI document as a guide for your initial HazCom training or subsequent HazCom training under 30 CFR Parts 46 and 482.

2 Federal Register, Volume #67, No. 120, June 21, 2002 [Page 42324]

Since the finalization of the rule and reference to the Z490.1 Standard, ASSE has had approximately 200 inquiries from SH&E professionals in the mining industry looking for information about the standard and its implementation. The rest of the article will provide an oversight of the standard, its scope, and how it addresses the general concepts of training.

The charter of the American National Standards Committee, Z490 Criteria for Best Practices in Safety, Health and Environmental Training, was accredited by the American National Standards Institute (ANSI) on April 1, 1998. The standard itself was approved by ANSI on July 2, 2001, and it grew out of the recognized need for improvement in safety, health, and environmental training. Quality training is required to ensure that workers and safety, health, and environmental professionals have the knowledge, skills, and abilities necessary to protect themselves and others in the workplace. Both the public and private sector have continued to wrestle with training issues on both an internal and external basis for many years. This includes everything from training requirements for specific standards to the potential accreditation of specific training programs.

The rationale ASSE offered ANSI in filing the application for establishing the project was that these safety, health, and environmental training standards would improve areas of competence, quality and effectiveness. The objective is to obtain standards of quality, which ensures that SH&E training providers meet such standards. The standards of Best Practice, now called Accepted Practice, can help employers and consumers of training services select quality safety and health training materials, instructors, and other program components. Once established, these standards can be used to audit, monitor, evaluate, analyze, etc. national, industry-wide training of large and small training service providers as well as for corporations and government entities seeking third-party review of their employee training activities.

Adding weight to this rationale was the approval of the ANS Z390.1-1995 (R- standard, Accepted Practices for H2S Training, where industry demonstrated its support for such training criteria. This validation presented convincing testimony to show that affected parties/interest groups would support these types of standards development. This translated to a committee whose membership you have just seen, which operates under ANSI rules and procedures.

Objectives of the Standard
A review of the foreword and explanatory sections clearly indicates that the ANSI accredited Z490 Committee has taken the position that safety, health, and environmental training is an important element of an effective and efficient overall safety, health, and environmental program. Historically, safety, health, and environmental training has been addressed by only a few regulations with limited scope, such as asbestos, hazard communication, and stormwater management. The regulations usually specify the technical requirements to be addressed in a training course, but do not stipulate how to adequately design, develop, deliver, and evaluate training. This Standard covers all facets of training, including training development, delivery, evaluation, and management of training and training programs. The Standard is intended and can apply to a broad range of training and training programs.

Of key importance is the fact that this standard provides a 30,000 foot view of safety, health, and environmental training. One of the issues brought up during committee debate was the Z490 standard is similar to many training standards. The view has been raised that it really does not have direct impact on specific applications of safety, health, and environmental training. Before going any further it is important to point again that the broad applications of the standard are designed that way by intent. It is not the intention of the Z490 Committee to attempt to address every aspect of safety, health, and environmental training in one comprehensive document. Such an approach would not be effective and would be a disservice to the key objectives we are trying to achieve.

The hope of the committee is that with this standard as a basic guideline, additional projects will provide training standards on specific applications. For example, the ANSI accredited Z359 Committee, Safety Requirements for Personal Fall Arrest Systems, Subsystems, and Components, is considering launching a project on training for fall protection systems in general industry. Effective training for fall protection is an issue the Z359 committee, the private sector, and government agencies such as OSHA continue to wrestle with. The possibility is there for the Z359 Committee to write a standard, which cites the Z490 standard, but can then specifically address the technical aspects of fall protection training. Such a process will empower more effective and efficient standards to be written for specific safety, health, and environmental training applications. Another existing example is the ANSI Z390 standard, Accepted Practices for Hydrogen Sulfide (H2S) Safety Training Programs. When the standard is revised during the next reaffirmation process, the Z390 Committee will be able to cite the Z490 Standard as a general guideline and then cite the technical specifics of H2S training.

Contents of the Standard
Point 1 means it is the first standard in the project series and, after .1, the year of approval. So it is titled ANSI Z490.1-2001 Criteria for Accepted Practices in Safety, Health, and Environmental Training. The words in the title capture the key words in the subject matter of the standard and also describe the standard in a shorthand fashion.

Section #1
The first section encompasses the Scope, Purpose, and Application sections of the standard. These stipulations are crucial to a voluntary national consensus standard since it establishes the extent and limitations of the standard. This includes:

  • Scope: This Standard establishes voluntary criteria for safety, health, and environmental training programs, including development, delivery, evaluation and program management.
  • Purpose: The purpose of this Standard is to provide accepted practices for safety, health, and environmental training.
  • Application: This Standard is recommended for voluntary application by training providers of safety, health, and environmental training. If any of the provisions of this Standard are deemed to not be applicable, the other requirements or recommendations of the Standard shall still apply. This Standard applies to all safety, health, or environmental training, whether separate or a portion of other training.

Section #2
The second section contains definitions addressing safety, health, and environmental training. These definitions were drawn from either existing materials or arrived at via consensus of the committee.

Section #3
The third section addresses training program administration and management. The committee members believe this is an important part of the standard since training programs are most effective and efficient when managed under a well-defined and organized administrative system. Such a system is designed to assure that training is in an integrated program, rather than a series of non-related training events.

Section #4
This section addresses training development and specifically provides criteria for training that will improve the occupational safety, health, or environmental knowledge, skills, or abilities used by the trainees in the performance of their jobs. This includes a needs assessment, learning objectives and prerequisites, course design, evaluation strategy, and commitment to continuous improvement

Section #5
Section #5 addresses training delivery. The purpose of this section is to describe acceptable criteria for safety, health, and environmental trainers, and to describe training material delivery requirements. This includes trainer criteria, training delivery, and feedback and communication.

Section #6
Section #6 addresses training evaluation. Training evaluation tools may measure trainee, trainer, training event, or training program performance. The standard provides guidance on evaluation approaches, and commitment to continuous improvement

Section #7
This section on documentation and record keeping generated significant discussion, as our intent is to provide guidance on a viable documentation and recordkeeping system that would maintain needed information while not creating a burdensome process. Certain regulations already require specific records to be kept for proof of completion of required training. Organizations also may desire to keep additional records to demonstrate their training efforts for control of potential liability issues.

The finals sections of the standard are informative annexes, which include:

Annex A - References
Annex B - Training Course Development Guidelines
Annex C - Training Delivery

Conclusion
For the first time, a general standard for safety, health and environmental training has been developed which will enable safety professionals to follow consistent training criteria applying to both the public and private sectors. Our hope is that the Z490.1 standard will function as a basic body of knowledge to train employees and compliance safety health officers, assist safety, health and environmental professionals in initiating successful cutting-edge programs, and provide a benchmark for employers to evaluate in-house and contracted training. The standard was developed from taking elements of accepted practices in the training industry and combining them with accepted practices from the safety, health and environmental fields. The result is a standard that provides a model of training that is transferable to every industry from material handling to construction. The standard's purpose is to serve as a benchmark for companies and government agencies in evaluating their training programs for new and current employees. The result will hopefully be lower number of injuries, illnesses, and fatalities through enhanced SH&E training programs.

If you are interested in purchasing a copy of the ANSI Z490.1 Standard it can be ordered through ASSE Customer Service at 847/699-2929. The current member Price is $32.00 with a List Price of $48.00. The order number is 3380.

If you should have any questions about Z490.1 please send them to the attention of tfisher@asse.org.