OSHA requires that all employees who may be exposed to hazardous chemicals receive training on the GHS system. This isn't optional — it's a federal requirement with real enforcement consequences.
Any employee who may be exposed to hazardous chemicals during normal work conditions or in foreseeable emergencies must receive training. This includes manufacturing workers, lab technicians, maintenance staff, warehouse workers, shipping/receiving, custodial staff, and healthcare workers.
OSHA requires training on several specific topics: how to read and understand GHS labels (including all six label elements), how to read and use Safety Data Sheets (all 16 sections), what the nine pictograms mean, the physical and health hazards of chemicals in the work area, protective measures and emergency procedures, and details of the employer's hazard communication program.
Initial training must occur before an employee begins work with hazardous chemicals. Additional training is required whenever a new chemical hazard is introduced into the work area or when the hazard communication program is updated. OSHA doesn't specify a mandatory retraining interval, but annual refresher training is considered best practice.
While OSHA doesn't explicitly require written training records for HazCom, maintaining documentation is strongly recommended. Records should include the date of training, topics covered, trainer name, and attendee signatures. These records are your evidence of compliance during inspections.
A quick way to assess your team's GHS readiness is our free GHS Symbol Quiz — it tests identification of all nine pictograms and can reveal knowledge gaps before an inspector does.
The most frequently cited training deficiencies include failure to explain pictogram priority rules (when one pictogram supersedes another), not covering the difference between "Danger" and "Warning" signal words, skipping the supplementary label elements, and not training on SDS Section 11 (Toxicological Information). Address these in your training program to avoid citations.