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.
According to the standard, to meet the minimum training requirements, each employee receiving PPE training must be trained to know at least the following:
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.
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 goal of explaining why is to increase employee motivation to use PPE properly.
Before an employee is allowed to do work requiring PPE, the employer must require each affected employee to:
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.
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.
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.
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.
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.
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.
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.
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.
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:
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."
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:
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.
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.
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.