The initial step in the KSA education process is to transfer knowledge about safety to learners. Next, we want to help them, through hands-on training, to use that knowledge to gain the needed skills to do their jobs safely.
The knowledge and skills that need to be gained by employees is summarized in OSHA Publication 2254, Training Requirements in OSHA Standards and Training Guidelines which discusses more than 100 OSHA safety and health standards that require some form of instruction and training.
Some safety instruction and all safety training require some form of evaluation to make sure employees have adequate knowledge, skills, and abilities (KSAs) to perform safely at work.
OK, let's look at this from another point of view. When OSHA inspectors show up for a safety inspection or, in a worst-case scenario, an accident investigation, you can bet they are going to ask employees questions about their job and watch them perform as they walk through the workplace. They may appear to be only looking at "things" in the workplace, but don't be fooled: they are watching everything that is happening. Remember, everything they see and hear educates them about the company.
One of the first areas the OSHA inspectors will evaluate, even before they walk the floor, will be the safety training program. They'll want to see your training documentation. They look at training before other programs because experience has taught them that if the safety training program does not meet minimum standards, overall compliance with OSHA requirements is not likely. OSHA compliance officers make some basic assumptions based on the education they receive:
General safety instruction is usually conducted as a course or meeting in the classroom, workfloor, or around the tailgate. Instruction may also be given through written notices, newsletters, or videos. Instruction may be quite effective when presenting required and "nice to know" information. For example, general safety instruction may include:
To document instruction, you usually only need an attendance roster. That's because students may not actually have to prove they've learned anything. If students do have to demonstrate they've learned something, an effective way to do that is with a written test because it formally documents results. Remember, as far as OSHA is concerned, "If it isn't in writing, it didn't get done." Also, the only training evaluation required is the student reaction survey or interview.
Safety training differs from safety instruction because it focuses improving "how-to" skills through practice. It takes what the student has learned during instruction and provides an opportunity, through practice, for the student to apply that knowledge.
An important consideration when developing safety instruction and training is to determine if OSHA requires a "demonstration" of adequate employee knowledge and skills as part of the training.
Technical "how-to" safety training that teaches employees how to do hazardous tasks and procedures 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.
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 on a job or if they have a deficiency in KSAs.
Let's look at examples of technical training on the next page.
Most OSHA training is technical in nature because it teaches employees how to do things. For instance, when reading about the training employers are required to provide regarding personal protective equipment (PPE) in 29 CFR 1910.132, we see that employers must cover the following topics:
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:
Some OSHA standards require that employees be trained by employers so that they gain the KSA'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.
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 does OSHA say about computer-based training (CBT) like this course? It's important to note that OSHA considers online 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 the instructor questions, and you must also pass a final exam.
OSHAcademy does 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 do things like use, care for, and how to detect defects in PPE.
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