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The committee discussed the issue of training and information outreach as a part of many different discussions. The Cooperation and Comparisons Work Group and its renamed version, the Training and Information Infrastructure Work Group (referred to as the Training Work Group in this chapter) identified useful sources of information and training. Many of the efforts are cooperative ones among different industries and between industry and labor.

9.2 SPEAKERS AND PRESENTATIONS

Darrell Mattheis, ORC, provided information about that organization's activities as well as the ORC document as a training tool. Committee member, Dr. John Howell explained the ILMA Product Stewardship Program. Tom Hanlon, United Technologies, as a member of the audience was invited to speak about websites (M6:36). Speakers on other issues addressed training as well. These speakers included: Dr. Cecile Rose, National Jewish Research and Medical Center; Dr. Daniel Goon, Castrol; Dr. Ed Stein, OSHA; Stephen Gauthier, a machinist at a large manufacturing facility on the East Coast; Thomas Slavin, Michelle Lantz, Caterpillar; and John Burke, Eaton Corp.

9.3 BACKGROUND INFORMATION

Training is a common requirement in OSHA standards and guidelines. The recent Industrial Truck Standard was cited by many members as an example of a comprehensive approach to training. Training is a major component of the Hazard Communication Standard. Stein explained that the recommendations in early OSHA and NIOSH work about dermatitis emphasized the need for training (M5:28). NIOSH also recommends training of employees who use MWFs (NIOSH, 1998).

9.4 REVIEW OF AVAILABLE INFORMATION

9.4.1 Experiences and Resources Related to the Need for Training and Information Outreach

Committee members noted the importance of training. Lick explained that inadequate training has led to over-reaction and worsened problems (M2:15). Howell noted that salesmen often do not have the expertise to aid customers with their MWF program (M4;4).

Education of users at all levels will have the best payoff, according to Howell (M5:16). Howell thought that initial expenditures for education and awareness should occur before engineering controls (M4:8).

Education has to be part of medical surveillance according to Lick and Newman (M5:31). Rose indicated that HP diagnosis is not covered adequately in many medical schools (M5:5). Wegman noted that better training of medical personnel on MWF related problems is needed to effectively address medical surveillance (M5:8). Rose stated that patients do not always know what symptoms to pay attention to and report in a questionnaire (M5:7).

Burch reported that the Cooperation and Comparison/Training and Information Infrastructure Work group listed the following groups as needing training: small businesses segmented by number of employees, operators, supervisors, senior management on the shop floor, unions, worker's compensation carriers, OSHA compliance officers, OSHA operating management, health and safety professionals, apprentices, trade associations, physicians (including primary care), compensation carriers and trade schools (M5:30; 8:3,20). Lick reported that the Systems Work Group added: suppliers, MWF managers, and tool makers to the list and stressed the importance of training compliance officers (M5:29; 8:1). Gauthier recommended not only teaching the new machinist about machining, but about MWFs as well (M8:19).

9.4.2 Existing, Developing and Needed Programs

9.4.2.1 0RC

Reports were made to the committee about the progress made by ORC in the area of training and information outreach (M5:30; 8:9). Mattheis explained that ORC is working with ILMA, AAMA and the Chemical Manufacturer's Association to develop a series of nationwide one day seminars for 1999 (M6:36). Low cost, one day seminars at universities with help from government funding and planning were recommended by Mattheis (M9:6). In addition, train the trainer programs are anticipated (M6:36). According to Mattheis, ORC planned to have education and outreach programs organized in every state by working together with OSHA, NIOSH, organized labor, universities and the business community (M9:6). Mattheis stressed the need to include labor and mid and small size business in ORC's development of education and outreach (M6:36). Local and national associations, local health department and other organizations could help provide participants and ORC would help with these efforts (M8:6). The seminars would include health issues but focus on fluid management and use the ORC Guide (M9:6).

The ORC document can be used as a centerpiece for outreach, training and education spearheaded by industry and White hoped labor as well (M8:6). Cox noted that it would be an excellent training tool (M8:7). Newman agreed that the document was a powerful teaching tool (M8:11). Newman thought it was more of a trainer's manual and recommended using simple terms like cough so workers would recognize if they had a problem (M8:11). According to Howell, the ORC document expands on what is needed by the Hazard Communication Standard, explaining what symptoms to expect and how workers can protect themselves (M:9:8).

9.4.2.2 ILMA Product Stewardship

Howell explained that ILMA's product stewardship program, ILMA MWFPSG at different times during the committee's deliberations (M4:4; 5:31). He explained that the program was finalized and a training session was provided in early May, 1999 (M9:11). Companies who participate will be committed to providing customers information and training on how to properly use MWFs in the workplace (M9:11). It is ILMA's view that products are safe as formulated and when used and managed as directed (Howell, 1998). Members reformulate when new health and safety data indicate it is prudent to do so (Howell, 1998).

The objectives of ILMA's program are: to demonstrate member companies' commitment to manufacturing and marketing safe and effective products; to enhance the safety and health of our own and our customer's employees; to develop sound, scientific peer reviewed data and to protect the environment (Howell, 1998). Additional goals include: development of educational materials; identification and addressing of potential data gaps; evaluation of potential risks; identification of work place factors affecting exposure; and development of a comprehensive product stewardship program (Howell, 1998).

A detailed written program for potential member companies has been put together (MWFPSG, 1999). The document "walks" the member through the program and provides a self assessment checklist and an extensive resource list (MWFPSG, 1999).

Wegman suggested that ILMA provide fluid specific training materials for customer's employees to avoid errors customers may make by developing their own training materials (M6:35). Howell noted that Burke's ideas for labeling and education would be taken back to the ILMA MWFPSG^SM (M6:35).

Training, product stewardship and dissemination of information are essential and Howell thought they could accomplish more in a shorter time than other options (M6:24). Howell viewed that the supplier was accountable for providing education and outreach to customers (M8:12). Product stewardship is also noted in Chapters Three and Six.

9.4.2.3. Medical Professionals

Wegman noted the importance of having a trained medical person involved in medical surveillance (M8:20).The Training Work Group noted the difficulty of providing information to physicians, especially family doctors (M8:20). Shortell noted that a very clear message to physicians about HP is needed (M5:30).

Teitelbaum explained that the best way to reach occupational physicians was through peer reviewed journal articles and teaching (M5:30). Wegman thought some materials about MWFs and disease should be sent to physicians

by the employer (M8:20). Burch noted that his organization had prepared a form for ADA for workers to take to physicians (M8:20). Sherman explained that some OSHA standards require the employer to provide information to physicians (M8:20). Anderson stated that the best teachable moment for physicians is when they are about to see a patient (M8:20). Anderson recommended that any employer form should not be too complex (M8:20). Cox explained that the Training Work Group did not want to make decisions for physicians but wanted to make sure physicians knew the relation between symptom, disease and MWF exposure (M8:20).

Anderson explained that a list of physicians by specialty can be obtained due to licensure (M8:20). He recommended targeting physicians who are seeing these patients, physicians who have a relationship with employers, and to use the OSHA consultation program (M8:20).

9.4.2.4 Industrial Hygienists and Safety Professionals

Kushner noted that health and safety professionals have done a poor job of communicating risk to employees and employers (M6:39). O'Brien was concerned that industrial hygienists do not know much about MWF systems management (M7:11). Lick disagreed noting that training can be accomplished through short courses (M7:11). According to Lick, industrial hygienists and safety engineers can be reached through their professional societies which offer conferences, and professional development courses (M5:30).

9.4.2.5 Courses and Websites

Burke explained that the Society for Manufacturing Engineers (SME) and the Society of Tribologists and Lubrication Engineers already have training courses that could be adapted to a certification standard (M6;30). Lick also noted courses by SME and other organizations and thought some vendors may view this as an entrepreneurial opportunity (M5:30).

Hanlin explained that the National Metal Finishing Resource Center has a listserve and people can send in questions and give responses (M6:36). He noted his company has an intranet MWF information resource with applications specifically for his company (M6:36). The intranet has hyperlinks to various sources including email links to individuals in the company that can help address specific problems (M6:36). White noted that many companies have intranet sites and this is a useful resource for distributing information within companies (M6:36). Day noted that all unions have websites and that they link to other sources (M6:36).The ILMA webpage provides a wide range of information, according to Howell (M4:4). Day noted OSHA's web page which includes presentations available for respiratory protection and fork trucks (M9:11).

The Cooperation and Comparisons/Training work group wanted to have a committee website separate from OSHA due to concerns about bias (M6:36). The work group recommended information such as members, links to organizations, charter, contacts at OSHA, minutes and linkage to the docket (M8:21). A bibliography would also be useful (M8:21). Sheehan volunteered West Chester University as a location for this website.

9.4.2.6 Labor/Industry Cooperative Efforts

The Chrysler/UAW training document on MWFs was received by the group (M6:23). Mirer explained that this booklet integrated with Hazard Communication training (M8:21). Current train the trainer activities do not usually include MWFs, according to Day, although he has incorporated MWFs into his training (M5:30). Gauthier provided some training materials that he has successfully used (M8:20).

Day includes MWF within the construct of the OSHA 30 hour courses which allow additional modules to be taught along with basic requirements (M9:11). Day explained OSHA local offices have resources as well as NIOSH (M9:11). Day noted that he distills out information from the NIOSH Criteria Document because this document is too involved for workers to read (M9:11).

9.4.2.7 Other Programs and Ideas

The Cooperations and Comparisons work group provided information on the SHARP program in Washington State (M3:15). This program provides a document Metalworking Fluids: A Resource for Employers and Health and Safety Personnel in Washington State (1997). The document summarizes health effects, components, and provides a self assessment tool for industry (Washington State, 1997).

Burch noted that some ISO activities on health and safety include training (M5:30). O'Brien stated that a new outreach program is starting at the NIOSH Morgantown office (M5:30; 6:36).

PMPA has a manufacturing fundamentals book for new hires that addresses MWF safety (M8:20). Other industry trade groups may also provide resources to their members.

Burke recommended training and certification of fluid specifiers and handlers (M6:29). He also suggested on-site manuals (M6:29). Mattheis explained that a proactive, thorough on-going educational program unlike any ever seen is needed (M5:24).

9.4.3 Material Safety Data Sheets

Teitelbaum was concerned about the adequacy of MSDSs (M1:2). He provided examples of ones he thought were inadequate (M5:21). He noted comments such as no harmful effects and that asthma and HP were not mentioned (M5:21).

Goon was concerned that Teitelbaum was judging formulators using an MSDS from a supplier to fluid formulators (M5:21). Goon felt that an MSDS is the wrong place to look for complete formulation information because manufacturers are not obligated to give this information (M5:21). Companies are concerned about proprietary information but will provide this information one-on-one, according to Goon (M5:21). Lick was concerned that only big companies can pressure formulators to do this (M5:22). Goon and Lucke agreed that the quality of MSDSs are poor in general in industry (M5:21). Howell noted that the quality varied among industries (M9:13).

Lick noted that the ANSI format is the appropriate one to use for MSDSs (M5:22; 9:13). An initial summary should be used and the format should be consistent and uniform (M9:13). Howell explained that only those components 1% or more of the total had to be listed on an MSDS (M5:22).

Burch agreed with Teitelbaum's ongoing concern about MSDSs (M9:13). He noted that small business takes the information from the MSDS and assumes it is accurate and trains from it (M9:13). Better MSDSs will result in better training (M9:13). He thought the MSDS was written more for legal protection than training (M9:13). Day cautioned against using MSDSs as the core of training (M9:13). Workers need to know how to read MSDSs but training to the chemical requires more information than an MSDS (M9:13). Lick noted common misconceptions about MSDSs such as thinking that it is appropriate to train from them (M9:13).

Additional references are cited in other Chapters and are also found in Attachment #6.

9.4.4 What Should be Included in Training

Burch reported for the Cooperation and Comparisons/Training and Information Infrastructure work group (M19). The group recommended that any training include: identification of the problem, development of goals, assembling of a program and materials, implementation and evaluation of the program, and improvement as needed (M8:19). The group noted that many of these components are part of Hazard Communication and other OSHA standards (M8:19). The recent industrial truck operating standard was cited because it provides for more specific training that reflects the work site and the previous experiences and training of the worker (M8:19). A training needs assessment should be done (M8:20). The frequency could follow the industrial truck standard and should involve an assessment of behavior to determine a need for training (M8:20). Training has to be fluid specific (M8:20). Checklists are good and retraining when conditions, risks, fluids change or at least annually would be appropriate (M8:20).

According to the Cooperation and Comparisons/Training and Information Infrastructure work group, training should be symptom driven and the symptoms linked to specific potential diseases (M8:20). Linkage of symptoms and disease to specific actions to take by the individual being trained is important (M8:20). Wegman urged explaining the work-relatedness of symptoms (M9:12).

The work group explained that any training would depend on the fluid, exposures and risk (M8:2). The approach and content would be different depending on the audience (M8:20). The issue of long term risks has to be addressed and how the fluids have changed over time (M8:20). Anderson explained that it was important to include information about cancer in training, especially regarding minimizing skin contact (M7:10).

Wegman suggested a preamble in the training section that identifies the health endpoints of concern which would guide most of the training effort (M8:20). Despite any disagreements on the relation of MWFs and symptoms, workers have to be trained on any relevant symptoms that are work related (M9:12). Mirer noted that whatever OSHA puts in a preamble of a standard or guideline would have to be addressed in training (M8:21). Any reputable statistically significant study has to be addressed (M8:21).

The Training Work Group recommended records such as training materials, attendance logs and evaluations checklists (M8;21). A three year retention may be appropriate and Sherman noted that as new training materials are developed they can replace the old ones (M8:21). Any recordkeeping should be done in a way to meet multiple uses by the employer (8:21).

The Training Work Group recommended integration of training under Hazard Communication (M9:11). Burch noted that the training document would supplement Hazard Communication unless the committee recommended training separate from this standard as part of a regulation (M9:12). Howell cited the Hazard Communication section H of 1910.1200, noting that what was emphasized by Wegman and Burch was included already (M9:12).

Burke recommended including information on: off work activities that cause problems, personal hygiene, good work practices and recognizing warning signs of disease (M6:30). Personal protective equipment training, as needed, could be included stated Burke (M6:30).

Sheehan urged the development of prototype training programs/ resources like the Chrysler/UAW booklet, so everyone does not have to start from scratch (M8:2). Lantz recommended warning individuals of special risks and cited her success with this approach (M8:12).

Gauthier thought that a comprehensive training program was needed and urged worker involvement in all actions (M8:18). His program was 40 minutes long and well received by workers (M8:18). Gauthier recommended not only teaching the new machinist about machining, but about MWFs as well (M8:19).

Day recommended some generic information for all audiences and more specific information for certain audiences (M9:11). How to recognize symptoms or an outbreak and what to do are important (M9:11). He did not know if everyone could buy into the same program (M9:11). Burch noted that there may be a variety of messages depending on the level of the audience, the type and size of plant, the fluids used, etc. (M9;11).

An improved delivery system is needed with existing documents made into how-to documents with bullet points for quick reading (M5:29). Lantz noted that in training sessions she distills the information into a few slides of do's and dont's as bullet points (M8:12). She urged quicker dissemination of the material to those who need it (M8:12). Lantz noted that it is important to teach people to be proactive so they can recognize a fluid problem and know who can help them solve it (M8:10).

Training on fluids management was discussed in the context of reviewing the ORC document. Slavin noted the importance of training but explained that the size of the system would dictate what would be included in training (M8:9). Training should included: machine safety, hazard communication, recognition of health effects and how to protect oneself according to Slavin (M8:9). How to recognize if a ventilation system is not working properly is important (M8:9). Proper addition and dilution of fluids and components must be understood (M8:9). Procedures for getting something fixed should be known by operators (M8:9).

9.5 CONCERNS AND LIMITATIONS

9.5.1 Size of Business

Burch explained that different training should be provided for different groups and different size businesses (M8:20). Certain basic concepts would be covered in any training with some specialized topics depending on system size, according to Slavin (M8:9).

Cox thought the ORC document was a fine teaching tool for small business (M8:12). He thought it should be read by the owner and foreman (M8:12).

Burch noted that training materials are held by many small businesses for the duration of employment (M8:21). These records document employee performance (M8:21).

Burch explained that for some small businesses, the OSHA on site consultants have made mistakes that were very costly (M9:13). As a result, some businesses do not have that much faith in these programs (M9:13).

9.5.2 Other Issues

McGee was concerned with Burke's recommendation for certification and wanted to know who would require uniform labeling and training and certification (M6:30). Burke thought that the MWF formulator trade associations should do the labeling and wanted a group of stakeholders to work out the certification and training issues (M6:30).

Howell noted that it would be difficult for one segment of the MWF community to provide all the information needed for training (M9:11). Besides the bias issue, no one has the whole perspective, according to Howell (M9:11)

Teitelbaum was concerned about workers who deny symptoms (M9:12). He worried about workplaces which discourage or penalize workers for reporting medical problems (M9:12).

9.6 LINKAGE OF DISCUSSIONS TO OSHA ACTION

Mattheis explained that a regulation without a strong education component would not work (M5:24). Burke recommended voluntary training for employees and that this training could help employees check on other employees (M6:30). Burke recommended certification with continuing education requirements (M6:30). Lick suggested considering forcing people to get training (M5:29).

NIOSH recommends training of workers to detect and report hazardous situations and to know how to protect themselves (NIOSH,1998). Good hygiene and housekeeping should be taught along with how to identify health effects associated with MWFs (NIOSH,1998).

9.7 COMMITTEE DECISIONS AND RATIONALE

At the fifth meeting, the committee voted unanimously to recommend to OSHA that prevention of illnesses from MWFs be included as one of the priorities for Susan Harwood targeted training grants in the next cycle (M5:30).

At the seventh meeting, the committee voted on the motion: that OSHA a) consider and respond to the committee's request to develop a targeted training program or programs which make use of training grants, but potentially other mechanisms and b) direct resources toward its on-site consultation program in both of these: i) in the area of MWF and issues of implementation of MWF programs and ii) providing advice and assistance with respect to MWFs (M7:37). All members were in favor of this motion (M7:38).

As a result of committee discussions the Cooperation and Comparisons/ Training and Information Infrastructure Work Group provided a summary of what should be included in a best practice training program.

The committee voted on its acceptance of what was provided by the training work group. The majority (14) voted for acceptance of this best practices document and one member (Burch) abstained.

Throughout many discussions of other issues, the importance of training was emphasized. Everyone involved with MWFs needs to know the potential health hazards involved, how to recognize signs and symptoms of disease, how fluids can be managed and are mismanaged, and how exposure can be controlled and contamination reduced. This coupled with the other best practices can reduce the deleterious effects of MWFs.

BEST PRACTICES FOR TRAINING

The committee identified that training has to be well organized, integrated into the existing requirements of the OSHA Hazard Communication Standard, and be specific to the individual circumstances of each facility. Although there are some common denominators, most training has to be geared to a specific audience. The committee recommended the following outline. The first two sections, A and B include items that should be part of all training and combined with the specific training as noted for specific groups.

A. Organization of Training Should Include:

1. A definition of audience and needs
   
   
2. The development of goals
   
   
3. High quality program materials
   
   
4. A determination of the frequency of training
   
   
5. Program implementation
   
   
6. Evaluation of the effectiveness of training and skill performance of employees assigned responsibilities for fluid management.
   
   
7. Program continuous improvement (M8:19-20).
   
   

B. Generic Training for Any Audience Should Include:

1. A description of MWFs and how MWFs become contaminated.
   
   
2. A description of good fluid maintenance practices.
   
   
3. Elements of the MWF Management Program for the facility, including the names of personnel responsible for the Program.
   
   
4. Recognition of symptoms and signs associated with exposure to MWFs and the added importance of symptoms when they appear in more than one worker.
   
   
5. In priority order, steps workers and other individuals can take to reduce exposures to MWFs.
   
   
6. Requirements of an OSHA Standard (if any).
   
   

C. Specific Employee/Apprentice Training Should Include in Addition to A & B:

1. How to reduce one's own exposure and maintain this reduction.
   
   
2. What to do and whom to contact if the individual has a MWF related symptom or determines that exposure control systems are not functioning adequately.
   
   
3. Information that is specific to the fluid and MWF system size (M8:2,20;9; 11 ).
   
   
4. Specific training to address behaviors that increase exposure to or contaminate MWFs.
   
   
5. The use of employee experiences with MWFs.
   
   
6. Specific training about the activities the individual has to do related to MWFs e.g. measurement of fluid concentration, pH, etc.
   
   
7. How to do any needed recordkeeping for MWFs.
   
   

C. Specific Employee/Apprentice Training Should Include in Addition to A & B (continued):

8. Integration with training required by the Hazard Communication Standard (M9:11).
   
   

D. Specific Training for Medical Professionals/Insurance Carriers Should Include:

1. How to recognize any symptoms related to MWFs, determine if symptoms are work related and link symptoms to specific potential diseases (M8:20).
   
   
2. How to diagnose and treat the symptoms and/or disease.
   
   
3. The significance of identifying more than one worker from a site with symptoms associated with MWF exposure and the needed response actions.
   
   
4. Procedures for medical removal.
   
   

E. Specific Training for Industrial Hygienists and Safety Professionals Should Include:

1. How to recognize any symptoms related to MWFs, determine if symptoms are work related and link symptoms to specific potential diseases (M8:20).
   
   
2. How to encourage employee reporting of symptoms etc.
   
   
3. The significance of identifying more than one worker from a site with symptoms associated with MWF exposure and the needed response actions.
   
   
4. How to qualitatively and quantitatively assess exposure.
   
   
5. How to compare to exposure limits.
   
   
6. How to identify fluid and mist problems and identify solutions.
   
   
7. How to develop a systems management team.
   
   
8. How to design and evaluate enclosure and ventilation systems for MWFs.
   
   
9. How to select and maintain mist collectors.
   
   
10. Additional sampling techniques such as bioaerosols, fluid parameters.
    
    
11. How to develop a MWF management program.
    
    
12. How to identify and change behaviors of employees and managers that lead to increased exposure.
    
    
13. How to do any needed recordkeeping for MWFs.
    
    
14. How to train employees about MWFs.
    
    

F. Specific Training for Supervisors/Managers Should Include:

1. How to recognize any symptoms related to MWFs, determine if symptoms are work related and link symptoms to specific potential diseases (M8:20).
   
   
2. How to encourage employee reporting of symptoms etc.
   
   
3. The significance of identifying more than one worker from a site with symptoms associated with MWF exposure and the needed response actions.
   
   
4. How to identify fluid and mist problems and identify solutions.
   
   
5. How to develop a systems management team.
   
   
6. How to develop an MWF management program.
   
   
7. Specific training about the activities the individual has to do related to MWFs, e.g., measurement of fluid concentration, pH, etc.
   
   
8. How to identify and change behaviors of employees and managers that lead to increased exposure.
   
   
9. How to do any needed recordkeeping for MWFs.
   
   
10. Procedures for medical removal.
    
    

G. Specific Training for Engineers Should Include:

1. How to identify fluid and mist problems and identify solutions.
   
   
2. How to develop a systems management team.
   
   
3. How to develop an MWF management program.
   
   
4. How to design overall fluid systems to minimize exposure and reduce fluid problems.
   
   
5. How to design enclosure and ventilation systems for MWFs.
   
   
6. How to select and maintain mist collectors.
   
   
7. How to minimize water and outdoor air pollution from MWFs.
   
   
8. Specific training about the activities the individual has to do related to MWFs, e.g., measurement of fluid concentration, pH, etc.
   
   
9. How to do any needed recordkeeping for MWFs.
   
   

H. Specific Training for OSHA Compliance Officers/Managers Should Include:

1. How to recognize any symptoms related to MWFs, determine if symptoms are work related and link symptoms to specific potential diseases (M8:20).
   
   
2. The significance of identifying more than one worker from a site with symptoms associated with MWF exposure and the needed response actions.
   
   
3. How to qualitatively and quantitatively assess exposure.
   
   
4. How to compare to exposure limits.
   
   
5. How to identify fluid and mist problems and identify solutions.
   
   
6. Additional sampling techniques such as bioaerosols, fluid parameters.
   
   
7. How to identify and change behaviors of employees and managers that lead to increased exposure.
   
   
8. How to interpret any needed recordkeeping for MWFs.
   
   

Appropriate training, as described in B and C in the above Best Practice, should be conducted 1) at the time of initial assignment; 2) when a new and significantly different physical or health hazard is introduced into the workplace, and 3) when new ways of protecting against recognized hazards or new engineering controls are introduced into the plant. Evaluation of the effectiveness of training should be conducted either annually or, in the alternative, periodically as appropriate to the facility. Retraining should be conducted as necessary.

Sample language for a training and education requirement for MWF, based on the HAZWOPER Standard (29 CFR 1910.120) is included in Attachment #10 of this report. Until such time that a standard is developed, training suggested in this Chapter could be accomplished under the requirements of the OSHA Hazard Communication Standard. The committee recommends that the items in B and C be included in any standard. The committee recognizes that some elements of the training could be accomplished under the OSHA Hazard Communication Standard.