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Course 709 - Personal Protective Equipment

Safety guides and audits to make your job as a safety professional easier

PPE Training Requirements

Introduction

Hazard Assessment
It looks like water and feels like water: must be water, right?

You are told to mix a certain chemical with water to use as a cleaning agent to wash down your company trucks. You check out the chemical. It looks like water, doesn't feel any different than water... so you assume PPE isn't really necessary. So, you go about washing the trucks. Your hands and arms get pretty wet with the solution you've mixed, but, heck... no pain, no sting... must be safe. No worse than water, right? Wrong, very wrong.

You've been using a mixture of hydrofluoric acid and water. By the time you get home your arms are hurting like crazy. You hurry off to the hospital, but by the time you arrive, it's too late. The hydrofluoric acid has penetrated your skin on both of your arms, clear through to the bone. Fluorine ions have replaced calcium ions in the bone, effectively turning it into a sponge-like consistency. But, you are lucky; only one arm must be amputated. The doctors were able to save the other arm.

This scenario would not have occurred had you been properly trained in using PPE. The PPE standard mandates that the employer must provide training to each employee who is required to use Personal Protective Equipment. But, what is effective PPE Training? What methods work, and what are the goals of training PPE? We'll try to answer these questions, and others, throughout this module so that you'll be better able to participate in, conduct, or manage PPE training that is beneficial to the employee and cost effective for the employer.

1. All employees who are required to wear PPE must _____.

a. be given a raise for hazardous duty
b. receive effective safety training
c. be at least 18 years of age
d. pay for the initial PPE

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What subjects must be trained?

Hazard Assessment
Don't forget to tell employees why it's important to wear PPE.

According to the standard, to meet the minimum training requirements, each employee receiving PPE training must be trained to know at least the following:

  1. when PPE is necessary;
  2. what PPE is necessary;
  3. how to properly don, doff, adjust, and wear PPE;
  4. the limitations of the PPE; and
  5. the proper care, maintenance, useful life, and disposal of the PPE.

So far, we meet minimum OSHA requirements... but one very important element is missing: The PPE standard does not specifically require education on "why" PPE is necessary.

So, why is this element so important? Because study after study tells us the most common reason employees don't follow rules in the workplace is because they don't know why the rules are important.

2. What is the most common reason employees don't comply with PPE safety rules?

a. They don't know why it's important to do so
b. They haven't been trained in the proper use of PPE
c. The employer doesn't conduct safety training
d. The quality of safety training is not adequate

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Educate "why"

Knowing why PPE is necessary is critical.

The first five elements in the list describe what PPE to use, when to use it, and how to use it. However, explaining why it's important to use PPE is as important as showing how to use it. If we neglect to explain why, we jeopardize the long-term effectiveness of the training.

The goal of the training is to increase both knowledge and skill> so that the employee is better able to properly use the PPE. The methods used to train the employee are primarily discussion and demonstration. To best way to measure employee knowledge and skills is to have the employee explain how to use the PPE while demonstrating how to use it.

Employees are taught why PPE is important by explaining the natural and system consequences.

  • The natural consequence of noncompliance includes some form of injury or illness.
  • The system consequences of noncompliance include discipline.

The goal of explaining why is to increase employee motivation to use PPE properly.

3. What is the best way to measure employee skills and knowledge about PPE?

a. The employee takes a written test
b. The employee explains and demonstrates PPE use
c. The employee signs an attendance roster
d. The employee responds to trainer questions

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Demonstration is the key

Before an employee is allowed to do work requiring PPE, the employer must require each affected employee to:

  • demonstrate an understanding of the training elements listed above; and
  • demonstrate the ability to use PPE properly.

Demonstration is really the most common and probably the most efficient method to determine employee knowledge and skills. How does the employee demonstrate an understanding of the six PPE training subjects listed above? Simple, their level of knowledge is measured by asking the employee questions similar to those listed below.

  1. What PPE is required for your particular job?
  2. When is the PPE required to be used in your job?
  3. What are the possible defects your PPE might have?
  4. How do you properly care for and maintain/store your PPE?
  5. What is the useful life of your PPE?
  6. From what hazards does the PPE protect you?

The form of the "test" may be either written or oral. If you are training a number of employees, you should give them a written test to best measure individual knowledge. It's also the intent of most OSHA law that knowledge be measured by written exams. In addition to the oral or written test, the standard requires some kind of method that provides an opportunity for the employee to demonstrate adequate skills. Here is a simple training strategy that ensures the student will have an opportunity to demonstrate.

4. When training a number of employees, each employee's knowledge and skills are best measured by _____.

a. conducting group oral exams
b. completing individual employee hands-on demonstration
c. administering written tests
d. conducting lectures and group exercises

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On-The-Job Training Strategy

On-The-Job Training (OJT) is the most common training strategy used in the workplace and for a good reason. OJT can be very effective because it tests both knowledge and skills during the training process. Let's take a look at the OJT steps.

Step 1. Introduction. State and discuss the learning objectives and answer any questions the employee may have. Discuss the acceptable standards of knowledge and performance. Tell the trainee what you´re going to train. Emphasize the importance of the procedure to the success of the production/service goals. Invite questions. Emphasize the natural and system consequences of their performance. The natural consequences describe the hurt or health that automatically results. The system consequences are those consequences the organization applies as a result of an employee's performance; discipline or positive recognition.

Step 2. Trainer tells and does. In this step the trainee becomes familiar with each work practice and why it is important. Review the initial conditions for the procedure. Demonstrate the process, carefully explaining each step as you go. Answer questions and continue to demonstrate and explain until the employee understands what to do, when and why to do it, and how to do it.

educate

Step 3. Learner tells - Trainer does. This step is necessary when exposure to hazards inherent in the procedure could cause serious harm. It protects the trainee because the trainer performs the procedure. The trainee explains the procedure to the trainer, while the trainer does it. This gives the trainer an opportunity to discover whether there were any misunderstandings in the previous step. The trainee also responds to trainer questions.

educate

5. Why is on-the-job training (OJT) the most common and effective safety training strategy?

a. It doesn't require experienced trainers
b. It tests both knowledge and skills
c. It is required by OSHA
d. It is the most cost-effective strategy

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The On-The-Job Training Strategy (Continued)

Step 4. Learner tells and does. The trainer has the trainee do it. The trainee performs the procedure but remains protected because the trainee explains and gets permission to do the step before proceeding to do it.

educate

Step 5. Conclusion. Recognize accomplishment - "Good job!" Reemphasize the importance of the procedure and how it fits into the overall process. Tie the training again to accountability by discussing the natural and system consequences of performance.

Step 6. Document.Training documentation should be more than an attendance sheet. Be sure to include the information below to properly document (certify) training in specific safety procedures and practices. Include all of the following even though OSHA rules tell you all that's required is name, subject, and date.

See the

  • Trainee's and trainer's name.
  • Date of training.
  • Subject(s) being trained - procedures, practices, related policies, rules, etc.
  • Certification - trainee and trainer signatures.
  • Trainee statement of understanding and intent to comply.
  • Trainee statement that he/she was provided opportunity to practice.
  • Trainer statement that testing of knowledge and skills was conducted.
  • Trainer statement that student demonstrated adequate knowledge and skill.

Step 7. Validate. At some point in time after the conclusion of the OJT session, observe and question the employee to validate that the training has been successful and that the employee has developed a proper attitude related to the work.

6. To validate on-the-job training has been successful, be sure to _____.

a. require a 70% pass rate on exams
b. repeat each step at least twice
c. have employees sign attendance sheets
d. observe and question employees

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Online Training

According to a recent letter of interpretation (2/4/09) about online training, OSHA states that an employer may not rely solely on the use of an online or video training program when training the use of PPE. According to OSHA, the trainee must be able to "don, doff, touch, feel and otherwise manipulate a particular piece of personal protective equipment that an employer may require or provide to protect their employees to prevent injury or illness." In addition to the online training (including this course), PPE training must also include a hands-on portion so that the employee can practice using the PPE.

Retraining Requirements

Training teaches how to use PPE.

When the employer has reason to believe that any affected employee who has already been trained does not have the understanding and skill required by the PPE standard, the employer must retrain the employee. Circumstances where retraining is required include, but are not limited to, situations where:

  • changes in the workplace render previous training obsolete;
  • changes in the types of PPE to be used render previous training obsolete; or
  • inadequacies in an affected employee's knowledge or use of assigned PPE indicate that the employee has not retained the requisite understanding or skill.

Conducting Training

Who will be conducting the training is a very important question. Whoever the person training PPE is, he or she needs to be an expert who not only understands how to use PPE correctly, but has a thorough understanding of the importance of doing so. It's critical that the employee understands the importance of wearing PPE, not only for their safety, but their "continuing employment."

7. Which circumstance below might require PPE retraining?

a. Changes in the community
b. Changes in PPE or job
c. Quarterly safety meeting
d. Initial safety orientation

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If it isn't in writing... it didn't happen!

To meet minimum OSHA rule requirements, the employer must verify that each affected employee has received and understood the required training. This must be done using a written certification that contains:

  1. the name of each employee trained;
  2. the date(s) of training; and
  3. the subject of the certification.

However, when it comes to documentation of PPE training, it's a good idea to go beyond the minimum requirements stated in the standard to make sure the employer can demonstrate (prove) they have met or exceeded their legal obligations with respect to safety training.

Solid PPE training documentation will contain the elements below.

  • A statement by the employee that they have received training by the employer on the six subjects listed above, and that the trainer has demonstrated proper use of the PPE and answered all employee questions about the PPE satisfactorily.
  • A statement by the trainer that, through oral/written test, the employee has satisfactorily demonstrated an understanding of the subjects covered during training, and has, through practice, demonstrated the ability to properly don, use, doff, care for, and maintain the PPE.

Below is a one example of training documentation. Your training documentation may look different, but it's very important that both the employee and trainer sign and date the document.

See the

Training Subject ______________________ Date _________ Location _______________

Trainee certification. I have received on-the-job training on those subjects listed (see lesson plan).

This training has provided me adequate opportunity to ask questions and practice procedures to determine and correct skill deficiencies. I understand that performing these procedures/practices safely is a condition of employment. I fully intend to comply with all safety and operational requirements discussed. I understand that failure to comply with these requirements may result in progressive discipline (or corrective actions) up to and including termination.

Employee Name Signature Date
______________ ______________ ______
______________ ______________ ______

Trainer certification. I have conducted orientation/on-the-job training to the employees(s) listed above. I have explained related procedures, practices and policies. Employees were each given opportunity to ask questions and practice procedures taught under my supervision. Based on each student's performance, I have determined that each employee trained has adequate knowledge and skills to safely perform these procedures/practices.

_____________
Trainer Name
__________________
Signature
__________________
Date

Last Words

Remember, PPE training is absolutely critical to an effective program. Effective training will likely prevent serious injury or even a fatality which makes it all worthwhile.

8. To meet minimum OSHA rule requirements, PPE training documentation must include each of the following EXCEPT _____.

a. the name of the employee trained
b. the date(s) of the training
c. the subject of the certification
d. certification by the trainer

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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