The emphasis the Occupational Safety and Health Administration (OSHA) places on education and training for accident prevention is demonstrated by the number of standards on the topic and the number of citations issued for lack of training.
OSHA offers more than 60 education and training requirements in OSHA construction standards and even more in General Industry. Many of these standards are applicable to activities performed by electrical contractors. It is critical to know what training is necessary and how to effectively administer it.
OSHA's training references vary. Each standard has specific instructions on the content that should be covered. The reference may simply be that the employer must have a certified, competent or qualified employee perform a particular task.
An example of this is the Ground Fault Protection standard [1926.404(b)(iii)(B)], which states, “The employer shall designate one or more competent persons.”
The term “designated employee” means one assigned by the employer or a representative qualified to perform those duties. Other standards such as the Gas Welding and Cutting standard (1926.350) go as far as describing that an employer must instruct employees that “valves on fuel gas cylinders shall not be opened more than 1_ turns.”
There are also variations in frequency of training and duration, instructor qualifications, training methods and documentation. The Hazard Waste Operations standard mandates that 40 hours of training be provided initially and an eight-hour refresher given annually. The same is true of instructor qualifications. The Training Requirements standard (1926.1060) for ladders mandates the instructor be a competent person.
The Powered Industrial Truck standard states that training must include hands-on instruction. Fall protection requires employers to document training by certification that includes the signature of the employer. As seen here, many standards offer no guidance on any of these details.
Deciphering training language
With the many regulations and differences in requirements, it is no wonder that a number of citations are appealed. The Occupational Safety and Health Review Commission (OSHRC) hears cases that go beyond the informal and formal hearing stages. The questions revolve around whether or not “all feasible steps were taken to avoid the occurrence of the hazard” and the adequacy of training.
Rather than trying to sift through the specifications of each standard to determine what training is needed and whether the instruction given is deemed adequate, the prudent approach is to focus on OSHA's voluntary guidelines for training.
Justification for this approach can be demonstrated by taking a look at two OSHA standards and one interpretation. The first standard offers the bottom line on topics to be addressed. The Safety Training and Education standard [1926.21(b)(2)] states, “The employer shall instruct each employee in the recognition and avoidance of unsafe conditions and the regulations applicable to his work environment to control or eliminate any hazards or other exposure to illness or injury.” Employers should be aware that regardless of the existence of a specific standard, there is a responsibility for training on all hazards.
The scaffolding standard
The second standard used as a reference is 1926.454-(Scaffolding) Training Requirements. It illustrates OSHA's expectations with respect to the results needed and efforts an employer must expend to achieve success. The standard states, “When the employer has reason to believe that an employee lacks the skill or understanding needed for safe work involving the erection, use or dismantling of scaffolds, the employer shall retrain each such employee so that the requisite proficiency is regained.” Training must achieve proficiency.
The response OSHA provided to an inquiry on the use of interactive training identifies the organization's thoughts on methodology. In a letter of interpretation, OSHA offered that any method may be used as long as results are achieved and employees have the ability to ask an instructor questions about the program and its content.
The voluntary guidelines (OSHA Publication 2254 “Training Requirements in OSHA Standards and Training Guidelines”) offer better explanations of OSHA's intent. The guidelines walk the employer through determining training needs and also offer a way to evaluate the training program and to make improvements.
The first step is determining if training is needed. Training offers little help in addressing certain hazards. Where possible, engineering controls should be used. Training efforts should target hazardous situations that come from an employee's lack of knowledge of a work process, equipment use or execution of a task.
Once it has been determined that training is needed, the next step is to identify what that training will be. The best source for training is a job hazard analysis. This is a process that breaks down the procedures for a particular job, studies the steps, and identifies hazards and controls. Other source content can come from accident records, job descriptions, industry data and information from employees knowledgeable about the job.
After the needs have been identified and sources for content have been found, the objectives can be developed. This must account for the employees' abilities and results needed. Objectives should be clear and must be stated in behavioral terms. For example, “Employees will climb a ladder using the three-point contact rule,” rather than “Employees will understand how to use a ladder.”
Staying on target
The goals and objectives are followed by development of learning activities. The key to selecting a learning activity is its relationship to the objective. If your objective is knowledge-based, lectures, videos or interactive sessions will work well. If a skill is needed, a demonstration or practice exercise is needed. Regardless of the method, the content offered must stay on target with the established objective.
With needs identified, objectives established and learning activities in hand, the training can be conducted. OSHA offers three recommendations to ensure the content is presented in a clear and organized manner: “(1) provide overviews of the material to be learned; (2) relate, wherever possible, the new information or skills to the employees' goals, interests or experience; and (3) reinforce what the employees learned by summarizing the program's objectives and the key points of information covered.”
The frequency, length of sessions, instructional techniques and instructor qualifications will be determined by the nature of the job and resources available. As with their interpretation letter on using interactive training, the guidelines emphasize the need for employee participation. Suggestions include discussions, asking questions, hands-on activities and role-playing.
Employee motivation cannot be overlooked. Employees must understand the importance of the training in helping them avoid injury. Training should be related to their interests and experiences.
The last two steps ensure the training meets its objectives. An evaluation should be performed and improvements made based on the evaluation. The best evidence of success are reduced injury and illness rates. However, one does not want to wait for this in hope of success. In addition, many variables can affect accident reduction. Management's commitment and productivity concerns have an impact. Training questionnaires and supervisors' observations of work performance can provide a more immediate measure and identify employees who put safety knowledge into action.
If training proves unsuccessful, program adjustments and retraining are needed. Consider the following: “(1) Were parts of the content already known and, therefore, unnecessary? (2) What material was confusing or distracting? (3) Was anything missing from the program? (4) What did the employees learn, and what did they fail to learn?”
The effort spent on safety training will be well worthwhile. Studies have shown that a correlation exists between high accident rates and poor training or none at all. Companies with reduced injury rates are committed to safety and provide extensive training. EC
O’CONNOR is with Intec, a safety consulting, training and publishing firm that offers on-site assistance and produces manuals, training videos and software for contractors. Based in Waverly, Pa., he can be reached at 607.624.7159 or firstname.lastname@example.org.