Two Types of OSH Education

If you review OSHA Publication 2254, Training Requirements in OSHA Standards and Training Guidelines, you'll discover that over 100 safety and health standards require some form of instruction and training. Most OSH instruction and training require some form of evaluation to make sure employees have adequate knowledge, skills, and abilities (KSA's) to perform their jobs safely.

With this in mind, it makes sense to develop a training model that ensures you:

• comply with the criteria within OSHA Pub 2254, and
• conform to consensus standard ANSI/ASSE Z490.1-2009, Criteria for Accepted Practices in Safety, Health, and Environmental Training guidelines.

In this training, we'll introduce you to an educational model that "fits" OSHA and ANSI requirements and evaluation criteria.

Later in the course, we'll also take a look at how to effectively evaluate the student and the training program using Kirkpatrick's Four Level Evaluation approach that is described ANSI/ASSE Z490.1-2009 guidelines.

Safety Instruction

General safety instruction is usually conducted using the lecture or discussion method. It may also be accomplished through written notices, newsletters, or videos. Instruction may be quite effective when presenting required or "nice to know" information. For example, general safety instruction might include:

• an overview of employer and employee responsibilities
• principles of root cause analysis
• introduction to the elements of our safety management system
• safety leadership principles
• introduction to the Employee Assistance Program
• engineering control basics

A typical instructional session might include watching a video about common hazards in the workplace or participating in some form of discussion. Employees may actually learn how to do something, but they usually don't have to prove it to anyone.

A simple attendance roster might suffice to document safety instruction. To get the course completion certificate, you may have to pass a written test, or all you may have to do is just show up. The only evaluation technique required is the student reaction survey or interview.

Technical Safety Training

One of the most important considerations when developing safety instruction and training is whether OSHA requires some sort of "demonstration" (test, evaluation) of employee knowledge and skills. Technical Safety training differs from safety instruction in that it is generally a "how-to experience." Safety training naturally includes instruction, but that instruction is focused on teaching you how to do something. That "something" is usually a hazardous task or procedure. Technical "how-to" safety training is actually the most common type of safety education. The training may be quite specific and usually requires some form of student hands-on participation or practice. In addition, evaluation of proficiency by testing of student performance in the learning environment is required.

Remember, even though an OSHA Standard does not specifically state or require that employees "demonstrate" proficiency, best practices in safety education may require that you include testing, practice and demonstration in a training session. Make sure you include hands-on practice and demonstration whenever employees might be injured if they have a deficiency in SKA's.

Let's look at an example on the next page...

Examples: Technical training topics

Most OSHA training is technical in nature because it teaches employees how to do things. For instance, when reading about training personal protective equipment (PPE) in 29 CFR 1910.132, we see that employers must cover the following topics:

• When PPE is necessary
• What PPE is necessary
• How to put on, remove, adjust, and wear PPE
• The limitations of PPE
• Care, maintenance, and disposal of PPE

Because there is a "how-to" requirement above, the training should include a demonstration and test to make sure each student actually has the ability to use the PPE properly.

More examples of Hands-on technical safety training include:

• how to use respirators
• how to remove a machine guard
• permit-required confined space entry procedures
• emergency evacuation procedures
• lockout-tagout procedures

Bottom line: If in doubt, test them out!

Some OSHA standards require that employees be trained by employers so that they gain the SKA's necessary to safely perform procedures and practices before they are exposed to related hazards in the workplace. Again, when you see the word, "demonstrate" in an OSHA standard, it means the employee must "prove" to the employer that he or she is proficient.

To earn a safety training certificate of completion employees should pass a test (preferably written) and/or skills demonstration in the learning environment. They can't earn a certificate by just showing up.

Certification

When employees successfully complete the safety training, the employer may certify them as "initially qualified" to perform procedures and practices. New employees should be closely supervised to make sure they can apply what they've learned to their job.

After successfully completing an initial period of evaluation by competent persons, employees should then (and only then) be certified by the employer as "fully qualified."

To document the training, the trainer and students should jointly certify (with a signature) completion of training. Also, remember, OSHA does not "certify" anyone as qualified to do "anything" in the workplace. The employer is ultimately responsible for certifying their own employees.

What about computer-based training (CBT)

What does OSHA say about computer-basted training (CBT) like this course? It's important to note that OSHA considers CBT training inadequate if it does not provide an opportunity for regular student-trainer interaction. OSHAcademy training does achieve the intent by providing an opportunity for you to ask an instructor questions in each module, and you must also pass a final exam.

I personally do not believe online training is adequate to meet all OSHA requirements for some "how-to" technical topics such as hazardous chemicals handling, lockout/tagout, confined space entry, etc. Online training fails to provide an OSHA-required opportunity to use equipment and practice hazardous procedures. Practice requires a real "hands-on" opportunity using more traditional in-house methods.

For instance, if you were to complete our Course 710, Lockout/Tagout, you would still need to complete a hands-on skill demonstration to prove you have gained adequate knowledge and skills to complete the LOTO procedure. Likewise, if you took Course 709, Personal Protective Equipment, you might have a good idea what PPE is, but you would still need to conduct hands-on practice to prove you have the skills to to things like use, care for, and detect defects in PPE.

REVIEW QUIZ

This is an open book review quiz. It's important to complete this quiz as some of the final exam questions are derived directly from the questions within this module quiz. Immediately after submitting the quiz, you will receive a web page containing your answers and the correct "book" answers.