Perhaps the most overlooked aspect of industrial safety is the need for proper training of workers and supervisors. OSHA addresses this need through a series of regulations—many industry-specific—and coursework through OSHA Outreach designed to help safety sink in.
OSHA Outreach courses are either 10 hours (for entry-level workers) or 30 hours (for supervisors or others with safety responsibilities). Content is delivered by independent trainers who meet OSHA’s requirements. Some courses are conducted in a classroom environment and many courses are taught online.
According to OSHA, employers should provide training not as a blanket solution to all safety and health issues, because engineering controls, proper OSHA-compliant safety signage and hazard abatement can make the need for training in certain subjects unnecessary. But some training and education are always required.
DuraNews recently spoke with Mark Moran, author of The OSHA Answer Book (now in its 11thedition), to ask him about OSHA training.
DuraNews: Does OSHA require that every employee be trained?
MM: OSHA’s General Duty Clause, to some extent, requires training for all jobs where a lack of training can lead to injuries. However, in certain cases, employers must provide adequate training before an employee begins a job, as is the case with operating a forklift. Some jobs require workers to be certified, competent or qualified to do a job. Construction, maritime, agriculture and general industry workers have specific requirements.
OSHA expects companies to produce written proof of a training program that addresses all aspects of safety, including fire safety, hazard communication and disaster plans. Dates, sign-in sheets and names must be recorded and kept for each training session provided.
DN: Why go with OSHA training instead of providing the training yourself?
Mark Moran: OSHA doesn’t insist companies take their training, but is very insistent employees are trained sufficiently. Some larger companies have the capacity for that—some even have their own training departments—but few are set up to provide 10- or 30-hour training. If an OSHA safety inspection occurs, the real question is “Was this employee properly trained?” and not “Did this employee receive our training.” With the authorized instructor, the assumption is that the training is thoroughly adequate, and there’s an official record that the training was done, should the training program ever be called into question by OSHA or the courts.
DN: What about companies that can’t afford in-depth training?
MM: Smaller companies generally won’t get audited by OSHA unless there’s a specific complaint or other specific safety problem that comes to light. So they can make the mistake of skipping training (and hope OSHA never knocks) or they can provide OSHA-accredited online training to their employees. If the company has resources for it, they can provide on-the-job training that fully addresses all risks and hazards present in their workplace.
DN: What are some of the specific risks that result from cutting corners?
MM: First of all, workers are placed at risk. Say your company works with hazardous materials but fails to adequately educate every employee about the health risks of every single chemical in the facility. An employee who has respiratory issues could open a container and suddenly find herself in the midst of a full-blown asthma attack. Had she known of the hazard beforehand, she would have informed her supervisor that she couldn’t be exposed to that material.
Secondly, there’s risk the company could be sued. If an employee can demonstrate he or she was not properly trained, that creates a great liability—a potential game-changer for a small business. And certainly workers’ comp claims can cause premiums to rise.
Large and mid-sized companies face those risks as well, plus they're much more likely to be visited by OSHA and receive a citation.
DN: What kind of fines are we talking about here?
MM: It’s considered a “serious violation” and could bring fines anywhere from $1,000 to $100,000, depending upon whether an employee was seriously hurt as a result of negligence in training.
DN: What do employers need to know about educating non-English-speaking or undereducated employees?
MM: Per OSHA, employees who receive job instruction in a foreign language must receive any Hazard Communication Standard information (or any safety information, for that matter) tailored to their language and literacy level. Courts have backed OSHA up on this.
DN: What are some of the most popular OSHA training courses?
MM: OSHA has annual or refresher requirements for several subjects, including bloodborne pathogens, asbestos, several chemicals and hazardous materials, grain handling, CPR, respiratory and even hearing protection. There are some annual agricultural training requirements like tractor rollover protective systems, machine guarding and cotton dust. This is by no means a complete list! But the annual requirement courses would probably be the most popular.
DN: So let’s say I’m an employer deciding whether to put my employees in a classroom course or in online training. How should I decide?
MM: Time and money are your two main considerations. Can you afford to take a team out of production and put them in class for a few days? Will the training offer enough value to actually prevent injuries and other mishaps, more than the online training? If so, go with the classroom course. Can you find or design adequate online training, and do you think your workforce will really learn what’s needed from it? Then go with online. You may well find that you can offer a combination of both. Weigh the liability of inadequate training against whatever it costs in time and money to have a properly trained workforce.
Mark Moran
Mark Moran is certified by the U.S. Department of Labor as an accredited instructor in compliance with OSHA requirements. He is president of Moran Associates, a management consulting firm that specializes in occupational safety and health.
Interested in educating yourself about OSHA's sign compliance standards? Request ourOSHA Safety Sign Best Practice Guide today.
Originally published here: http://www.duralabel.com/duranews/2013/jan/osha-training-what-every-employer-should-know
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