Safety Training Tips & Best Practices
Numerous, specific federal OSHA standards require that employees receive training. In the standards book (29 CFR 1910 for General Industry, including heat treaters and related industries), the table of contents does not list general “training” headings. However, in the 1910 index, under “Training Personnel,” several particular standards are referenced. Also helpful (although possibly not quite 100% up-to-date), I recommend that you obtain OSHA’s “Training Requirements in OSHA Standards.” You can simply download this document, from the link, found within the osha.gov site: https://www.osha.gov/Publications/osha2254.pdf
[As always, please remember that your state government/OSHA— rather than the U. S. Department of Labor— may be the enforcing authority for your facility. If so, it is conceivable that you are required to comply with additional training standards.]
The “Training Requirements in OSHA Standards” publication is an across-the-board, dedicated publication, which (ostensibly) contains every reference to training in the standards. OSHA-mandated or not, all employees should receive at least basic safety and health training. OSHA-dictated training requirements are not the “end all.” You must decide what topics (and to what degree) should be included in orientation programs, even when not legally obligated.
The orientation program should include a well-structured session dealing with fundamentals of safety and health on the job. From the first day forward, employees should be convinced to have positive expectations about training. Thus, they will look forward to training sessions and feel that, as participants, they are an integral part (and benefactors) of an important process. Their interest and attention can be captured when they view training (as offered by/through their employer) as a fruitful and useful experience. To set the proper tone, I recommend that someone from upper management introduce the training to demonstrate his/her support. Then the session should turn to the types of hazards particularly relevant to the work at the establishment. At times, this extends to work done away from the facility.
The trainees must have a secure feeling that the training was designed with their well-being in mind. This is not simply time set aside so that some government rule can be checked off. It must be made abundantly clear that the company will do its utmost to provide a safe and healthful workplace. No matter how effective training can be, it is not a substitute for safe working conditions. For instance, training should not have to include in-depth warnings to work carefully around unguarded machinery or to walk carefully when descending stairs that lack railings. The machines should be guarded, and the stairs should have railings.
Trainers must be absolutely clear that trainees “get it.” They must assure that trainees understand the purpose and objective of the training, and why and how it will be useful to them. Rationale should be explained. Whenever the need for particular conditions or actions is discussed, the trainees must be told exactly why sound safety principles and practices (not just company or government officials) dictate that those conditions and actions are required. Potential injury and illness consequences of non-compliance must be spelled out. There should be no doubt that even skilled, experienced, intelligent, “tough” employees can be hurt if not performing in the prescribed manner.
Once your company has hired a person, you should make it clear that you realize that he/she may not fully understand the work assignments until trained. Sure, there are times that companies are only seeking someone who is totally familiar with a job. That is a different story, but even if the new hire has apparently impeccable credentials and is to join your firm in a highly technical and professional capacity, he or she still needs to go through an orientation.
Despite the trainer’s assurance to the employee that questions are welcomed, and the employee will not be fired just because he/she fails to fully grasp all relevant points immediately, human ego, fear of embarrassment, and anxiety that they will be let go still often remain. When you ask employees if they “get it,” they may say “no” the first time and possibly the second. They might say “yes” after that, even if your points are still not fully understood. You must assure that the information that you have imparted has been completely received and absorbed. Do not worry about being condescending. You would hate to look back, after a serious injury that resulted due to a lack of comprehension, and think that if you had just taken a little more time to guarantee the transfer of information, the injury would not have occurred.
You should be unambiguous in your urging that, if employees have questions, whether one hour or three months after the training session, they should come forward and seek clarification. You might ask that the trainee repeat the information. You might ask that the trainee demonstrate (in a controlled situation, so as to avoid injury) the correct way of carrying out the job assignment. The point is lost if the trainee properly demonstrates, simply to please or fool the trainer, and then performs unsafely when back on the job. So, feedback is required from the foreperson, if a trainee who has completed the course fails to act as taught.
If employees are to receive training related to (for instance) a specific OSHA standard, that training must be tailored to specific hazards that those employees may face. For example, hazard communication (chemical) training cannot simply consist of a general explanation of the dangers presented by chemicals. The training must describe the hazards, precautions, emergency responses, and so on directly tied to the particular chemicals with which those employees work or to which they might otherwise be exposed. The training must cover the particular uses and handling techniques of those chemicals (not just “liquids”; consider vapors, fumes, compressed gases, welding rods, tars, adhesives, abrasive wheels, and much more!).
Permit-required confined spaces serve as another example of when training calls for significant detail. The actual steps to be taken, for employee protection, can differ for each distinct confined space. Those steps must be taught. It must be made clear that the steps taken for one confined space cannot be assumed to be safe and adequate for another. If there is training for powered industrial vehicle operation, it must include the safe driving methods and special hazards relating to specific vehicles. One type of forklift truck may operate and handle differently than another vehicle, and hence require different special precautions even if the other one performs a similar function.
Your plans for training should be coordinated with the personnel department. It is advantageous to avoid staggered hiring, which results in (for instance) two persons starting work on the 1st of the month, three on the 5th, and two more on the 8th. It is much easier, and more practical, to have them start at the same time so they can be trained at once. Otherwise, the proven tendency is not to train the earlier-hired persons, until the last of the group has reported for work. That puts new employees, and possibly those that they might endanger, in jeopardy until the last hire is brought on board. I worked with a company that received an OSHA visit the very day that a particular employee began employment there. She worked in a machine shop, where she was likely to have skin contact with coolant in a trough. She had not received hazard communication training regarding that chemical, or any other to which she could be exposed. The company (deservedly) received a citation. As it turned out (and OSHA discerned), the employee suffered from an existing skin condition.
One idea rarely implemented, but that can have great positive pay back, is to periodically hand out short, simple survey forms. These questionnaires are designed to gather input on what training the employees feel is needed. The forms should not be signed. They may be filled out on company time, if so desired by employees. Questions would address whether any aspects of their jobs frighten them, whether they are unsure about how to perform tasks safely, and whether they feel there are unsafe conditions that cannot be brought to an acceptable level, even when they perform their duties as directed. The questionnaire can also address whether employees have experienced any close calls or witnessed others having experience close calls.
Written by: Rick Kaletsky, MTI Safety Consultant - rkaletsky@gmail.com