News & Information Blog

Part 1: Providing the Right Information

I can't tell you how many times I had to write the following violation of the Hazard Communication standard when I was in OSHA standard enforcement.

Code Section(s) Violated: 1910.1200(h)(1) Employers shall provide employees with effective information and training on hazardous chemicals in their work area at the time of their initial assignment, and whenever a new chemical hazard the employees have not previously been trained about is introduced into their work area. Information and training may be designed to cover categories of hazards (e.g., flammability, carcinogenicity) or specific chemicals. Chemical-specific information must always be available through labels and safety data sheets.

I'd walk into the employee work areas and ask them to:

• Describe the hazards of the chemicals they worked with
• The safe work practices employed
• The controls they used to reduce their exposure

Over 20 years I've found that employees who were able to answer that question had some part of their training conducted within their work area, not just in the classroom.

In standard after standard OSHA uses language that makes it clear generic classroom or online training is not enough. For example:

Training requirements for walking working surfaces

1910.30(a)(3)(i) The nature of the fall hazards in the work area and how to recognize them;
1910.30(a)(3)(ii) The procedures to be followed to minimize those hazards;

Training requirements for powered platforms for building maintenance

1910.66(i)(1)(i) Working platforms shall be operated only by persons who are proficient in the operation, safe use and inspection of the particular working platform to be operated.

Training for Personal Protective Equipment

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.

Part 2: Helping Connect the Employee's Training to Their Personal Safety

Where does your safety training take place? In a class or conference room with a live presenter? Are the employees sent to Human Resources to sit in front of a computer to watch a training deck with a voice over and a quiz at the end.

Usually, the employee leaves their work area and goes elsewhere for his/her safety training. If the employer provides no concrete connection between the training and the employee?s work area safety becomes external to their job.

While it?s an efficient way to get through training and check off a box on the safety to do list, it can give the employee the impression that safety is a low priority - get it done and move on. This creates unintended and long-term consequences, such as ignoring compliance with safety rules that may get in the way of production or de-emphasizing rules that are not popular or convenient. Developing a sustainable thriving safety culture can quickly be derailed or just fade on the vine.

Part 3: Safety Training as a Primary Tool in Loss Prevention

The Hazard Communication standard says that you can train employees in hazards by category. But the following work area specific information is also required:

1910.1200(h)(3)(iii) The measures employees can take to protect themselves from these hazards, including specific procedures the employer has implemented to protect employees from exposure to hazardous chemicals, such as:

• Appropriate work practices
• Emergency procedures
• Personal protective equipment to be used

1910.1200(h)(3)(i) Methods and observations that may be used to detect the presence or release of a hazardous chemical in the work area (such as monitoring conducted by the employer, continuous monitoring devices, visual appearance or odor of hazardous chemicals when being released, etc.);

• Hurt themselves or others
• Damage your property
• Slow down production

Face it, if you added the specific information each employee requires to meet those goals, large chunks of the presentation would be irrelevant to the majority of the trainees. Add to that the time they would not be working on the production line.

The fastest and most effective way to connect the classroom to the work area is by having someone, their supervisor, the Safety Manager, a Safety Committee member, an experienced and vetted co-worker, etc., give them the required specific procedures and information when they return from watching training to the work area.

Not only does this ensure they get the specifics they need, but you verify that the employee learned what they were required to know. Documentation that the training was complete and compliant requires a sign off from the person conducting Part 2 of the training.

By breaking the training into two parts, the general hazard information and the work area/job specific training, you reduce the time in the classroom and provide the employee with information he finds directly useful.

Think of it this way, instead of knowing that some processes in the plant generate combustible dust he knows one of the processes he runs creates dust that becomes combustible at 25% airborne concentration. So, if the ventilation fails he must stop the process to reduce the risk of fire.