Effective Employee Training
By Susen Trail | 04/07/2021
Our Blog today takes you behind the scene to hear how a retired Safety and Health Officer evaluates the effectiveness your employee’s training. It’s a bit diabolical.
What OSHA Considers Effective Employee Training
Do you remember getting your driver's license? You didn’t just walk into the Department of Motor Vehicles guess your way through a test, get a snazzy picture and walk out ready to drive your city's streets. You had to take the test, get the theory right, then demonstrate that you understood the practice.
Many employers are missing the point of OSHA required training by using 'canned' presentations purchased from a company and many never include the hazards and safe guards specific to their facility - it’s like a movie of people driving cars. Even more employers don't verify the information translates to safe behaviors in the workplace.
When it comes to training, OSHA has few requirements on how you provide the training. Each standard requiring training is usually very clear that the training must include information specific as to your workplace and, at a minimum, what must be absorbed, implemented, and retained by the employee.
A few examples....
The ladder standard:
1910.30(a)(3)(i) The nature of the fall hazards in the work area and how to recognize them.
Process Safety Management standard:
1910.119(g)(1)(i) ……The training shall include emphasis on the specific safety and health hazards, emergency operations including shutdown, and safe work practices applicable to the employee's job tasks.
1910.119(g)(3) Training documentation. The employer shall ascertain that each employee involved in operating a process has received and understood the training required by this paragraph. The employer shall prepare a record which contains the identity of the employee, the date of training, and the means used to verify that the employee understood the training.
Personal Protective Equipment standard:
1910.132(f)(2) Each affected employee shall demonstrate an understanding of the training specified in paragraph (f)(1) of this section, and the ability to use PPE properly, before being allowed to perform work requiring the use of PPE.
Enforcement example:
When I was in Compliance I would walk up to an employee working with a chemical and ask them to identify its hazards and how they were trained to protect themselves when working with that chemical. If they don't know, as sometimes the employee gets nervous, I'd ask them to find the Safety Data Sheet and I'd observe the following:
- How long it takes them to find the SDS in the book.
- Do they know how the SDS' are organized in the book?
- Can they locate the section of the SDS relating the hazards and the section relating PPE?
- Do they know how to dispose of empty containers?
I'd glance at my watch to set a start time. If it takes an employee more than five minutes to get to the information they need to work safely then most employees won't seek it out. If the employee does not know how the hazards are controlled, or can't find the hazard information within a few minutes, you are cited for ineffective training.
A good CoSHO will ask at least two employees in different areas. A good Safety Manager will be encouraging but not lead the 'witness'. If you have employees with a language barrier or impairment this is the time to showcase your solution! This might be a coworker nearby assigned to provide the assistance required for the same access to information as every other employee. In fact, their 'assistant' should have noticed the conversation and be at the employee's side within about 30 seconds, or half the time of the average stop light...and you know how long that is!
Some standards require documentation of training and some do not. I've had Safety Managers show me documentation that the employee who failed the quiz had signed the attendance sheet for training the week before. It does not matter if the training was ineffective for only that employee because, when he is working with, say, dangerous chemicals, he or she is a danger to themselves and others.