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Safety Instruction and Training

First Things First

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This is OSHA's Bible for Safety Training.

The three-phase sequence of education in the KSA learning process is as follows:

  1. transfer knowledge (K) about safety to learners through instruction;
  2. conduct hands-on training that uses that knowledge to gain the initial skills (S) needed to do a task; and
  3. using the skills on the job to gain experience and improve abilities (A) so that the learner can excel.

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.

How to Impress OSHA

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:

  • If they ask employees questions, and all they get are shrugs or "I don't know," you can bet that the inspectors are also going to take a closer look at conditions in the workplace.
  • If they ask employees about safety, and they get knowledgeable responses and see skilled employees, they are very impressed and that bodes well for the overall inspection.

1. What is the three-phase sequence in the KSA learning process?

a. Training, Knowledge, Abilities (TKA)
b. Knowledge, Skills, Abilities (KSA)
c. Skills, Abilities, Knowledge (SAK)
d. Abilities, Knowledge, Skills (AKS)

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Safety Instruction

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General safety instruction is usually conducted as a course or meeting.

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:

  • Employee safety orientation;
  • The steps in a root cause analysis;
  • Introduction to the elements of our safety management system;
  • Process safety management principles;
  • Employee Assistance Program management; or
  • Engineering control basics.

Documenting Safety Instruction

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.

2. "Principles of Safety Management" would be a topic presented in safety _____.

a. demonstration
b. practice
c. training
d. instruction

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Safety Training

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Safety training provides an opportunity, through practice, for the student to apply the knowledge.

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.

Click on the link to see a comprehensive list of OSHA training requirements.

Let's look at examples of technical training on the next page.

3. How does safety training differ from safety instruction?

a. It focuses on gaining general knowledge about safety
b. It is longer and is usually conducted in the classroom
c. It doesn't require a written test to pass the course
d. It is specific and usually includes hands-on practice

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Examples: Technical Training Topics

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Training should include a demonstration and test to make sure each student can use the PPE properly.

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:

  • when PPE is necessary;
  • what PPE is necessary;
  • how to put on, remove, adjust, and wear PPE;
  • the limitations of PPE; and
  • 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; or
  • lockout-tagout procedures.

4. Which educational strategy is the most common form presented in the workplace?

a. Technical safety training
b. General safety instruction
c. Operational safety instruction
d. Management safety training

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Bottom Line: If in doubt, Test them out!

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The employee must "prove" to the employer that he or she is proficient in a certain task.

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.

Documentation

Initial Qualification: 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.

Full Qualification: When employees successfully complete an initial period of evaluation after completion of training 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.

5. When can competent persons certify employees as fully qualified to perform hazardous tasks and procedures?

a. When employees pass a written exam and sign the attendance roster
b. When employees complete a period of evaluation after training
c. When employees complete three months on the job
d. When employees can talk "safety" in their own words

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Computer-based Training (CBT)

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Online training must offer regular student-trainer interaction.

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.

6. What is a primary OSHA criterion for online safety training?

a. It must be presented in English or Spanish
b. It must provide an opportunity for students to ask questions and get responses
c. It must take the form of video or slide presentations
d. It must be at least 10 to 30 hours in duration

Check your Work

Read the material in each section to find the correct answer to each quiz question. After answering all the questions, click on the "Check Quiz Answers" button to grade your quiz and see your score. You will receive a message if you forgot to answer one of the questions. After clicking the button, the questions you missed will be listed below. You can correct any missed questions and check your answers again.

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Wrong Way Right Way: Safety Cases

Watch this video by DuPont Safety Training.

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