Yeah, that’s a really good Q. First, I’m glad u didn’t ask about “required annual WHMIS training.” There is no such requirement. WHMIS training has no pre-determined shelf life. It lasts as long as the training remains timely and reflective of current conditions and hazards. New/Refresher training is required only when and if:
- Work conditions change in a way that alters the exposure risks covered in the previous training;
- New and significant hazard information about the hazardous product becomes available after training takes place;
- Periodic evaluations indicate that workers don’t have adequate knowledge to apply their training; and/or
- There are other indications that the previous training isn’t effective and needs refreshing.
Best Practice: You don’t necessarily have to provide refresher training every year but what you SHOULD do, IMHO, is consider whether training needs to be refreshed as part of your annual WHMIS REVIEW. Unlike training, WHMIS program review IS required once a year and it should include a review of how effective and timely your current/most recent WHMIS training is and determine who needs refresher training in accordance with above criteria.
There’s a bunch of stuff on OHSI that gets into the nitty gritty about how to provide WHMIS training and, very importantly, verify that it’s effective and understood by trainees. Hope that helps. Good Qs. Glenn
