Back to Final Report Metalworking Fluids Standards Advisory Committee
9.1 GENERAL INFORMATION
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.
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.
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).
9.4.1 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
184.108.40.206 0RC9.4.3 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).
9.5.1 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).
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).
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.
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:
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.