Training and Education
Deploy the CSMS
After the development phase is completed, deploy the completed CSMS plan so that everyone has it and can take action. However, to make sure everyone understands the CSMS, educate everyone on the components of the CSMS and their personal responsibilities within each component.
It’s very important to make sure the following training occurs:
- Management and supervisors commitment and leadership responsibilities
- Train-the-Trainer courses for those who will be conducting classroom and on-the-job (OJT) safety training
- Employee technical training by qualified safety trainers
After completing the training, make sure it is properly documented. Remember, as far as OSHA is concerned, “if it isn’t in writing, it didn’t get done.” Once training is completed, it’s time to officially deploy the CSMS.
To make sure the deployment was successful, do the following:
- Get feedback from everyone on the success of the deployment
- Analyze the results of the deployment after a year
- With the data gathered from your analysis, evaluate the success of the deployment
- Implement a long-term “continuous improvement” strategic plan
Orientation and Training
Each construction worker must receive adequate safety orientation, general instruction and technical training on applicable OSHA standards, company safety requirements, and hazardous procedures to do his or her job safely. You should also evaluate safety training and performance periodically to make sure everyone understands their safety responsibilities as well as related OSHA standards.
How to Monitor Worksite Safety Training
Your company should provide training to protect your employees and to assure OSHA requirements for construction workers are met. It will also be very important to continuously monitor the effectiveness of employee training needs to keep workers safe and healthy on the job. To do that, make sure employees are being observed regularly by supervisors and safety staff.
Use observation, interviews and written exams as necessary to make sure:
- all employees, including contractors, understand the hazards to which they may be exposed and how to prevent harm to themselves and others
- supervisors and managers understand their responsibilities and the reasons for them so that they can carry out their roles effectively
- periodic refresher training is conducted for all employees as necessary
- workers are trained on first aid and how to respond to emergencies on the worksite
New Employee Orientation
New employees should receive orientation training on your company’s CSMS, safe work practices and expectations, and specific safety training for the tasks that they will perform.
- After inspecting a job site, a designated person should identify and evaluate all potential hazards for potential of serious injuries and probability of an accident. Actions will be taken to minimize the hazards and protect the workers.
- The Safety Coordinator or other designated site safety person will appraise the skill and knowledge level of exposed workers, and provide any needed training.
- Where Safety training is needed, appropriate training should be provided.
- Hazards should be identified.
- Necessary precautions will be explained.
- Training length and level of detail should be determined by the severity of the hazards and the requirements of OSHA.
- Records should be maintained for all training sessions with descriptions of topics covered and names of workers trained.
An effective safety program is designed around the processes, procedures, and practices normally assigned to employees and integrates safety-related decisions and precautions into them.
On-the-Job (OJT) Training
The purpose of OJT is to provide the employee with task-specific knowledge and skills in his or her job/work area. The knowledge and skills presented during on-the-job training are directly related to those they will perform on the job.
OJT can be one of the best training methods because it is planned, organized, and can be conducted at the employee's worksite. OJT is generally the most common method used to broaden employee skills and increase productivity. It is particularly appropriate for developing skills unique to an employee's job. And, did you know that most safety training requires hands-on practice and demonstration, so OJT is a great way to make sure you meet OSHA expectations.
Toolbox talks should be conducted regularly (weekly or daily).
Topics covered should include:
- The safe work practices necessary for that day’s work.
- Any safety concerns workers may have.
- Brief refresher training on relevant safety topics
One of the best ways to keep both the employer and all employees safe is to ensure strong safety training documentation. It's not just a good idea for the employer to keep complete and accurate records of all safety and health training; it's required by more than 100 OSHA standards. It’s also recommended by ANSI Z490.1-2009.
Records can provide evidence of the employer’s good faith effort to comply with OSHA standards. Strong documentation can also help the employer defend against claims of negligence. Documentation can also supply an answer to one of the first questions an accident investigator will ask: “Was the injured employee adequately trained to do the job?”
If your training or safety meeting presents general information related to safety it's most likely considered safety "instruction." When conducting general safety instruction, we may not need to evaluate employee performance to determine ability to perform specific hazardous procedures. It may be perfectly fine to use a simple attendance roster to document the training. An attendance roster may include the following information:
- names attendees
- other identifying information
Formal Certification of Training
When OSHA or any safety training requires employees to demonstrate knowledge and skills in performing hazardous procedures or using safe practices, an attendance roster may not be legally sufficient to document the training.
Technical safety training should include testing and formal (written) certification. Certification of training usually involves issuing a certificate of competency or qualification.
According to ANSI Z490.1-2009, Section 7.4, Issuing Certificates, recommended certification of training should include:
- trainee's name
- course title
- date, location and hours of instruction
- statement that the trainee has successfully completed the course
- name and address of training provider
- date periodic refresher training is due (if required) or expiration date
- a unique trainee identification number
- the level of training or type of certificate awarded
- any other information required by regulation
- number of credits (CECs, CEUs, etc.), if issued. Make sure employees have met all requirements for credits.
To make your documentation stronger, you may want to consider including the following information:
- trainee statement that he/she was provided opportunity to ask questions and perform procedures and practices.
- trainer statement that trainees, through testing, demonstrated adequate knowledge.
- trainer statement that measurement (testing) of knowledge and skills was conducted and that trainees met or exceeded required levels of performance.
- trainee statement of intent to comply with the procedures, practices, policies, and rules.
- trainee statement of understanding that failure to comply may result in discipline.
- a list or description of the specific subject(s) being trained. Describe the safety procedures, practices, policies, rules addressed in training.
- a list or description of the specific procedures practiced in the learning environment.
- certification - a place for trainee and trainer signatures.
Sample Training Certification - Page 1
Training Subject ____________________ Date _________ Location _______________
Trainee Certification of Training. I have received on-the-job training on those subjects listed (see other side of this sheet): 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 of Competency. I have conducted orientation/on-the-job training to each employee listed above. I have explained related procedures, practices and policies. Each employee was given opportunity to ask questions and practice procedures in the learning environment. 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
Supervisor Certification of Competency. I observed/interviewed the above employees on __________ date(s). Each employee has demonstrated adequate knowledge and skills to safely perform all steps of the procedures/practices in the work environment (at their workstation, worksite, etc.).
________________ ________________ _________________
Supervisor Name Signature Date
Notice that supervisor certification of competency is included as part of the training document. This certification evaluates employee knowledge and skills in the actual work environment. Including this will help ensure employees are "fully qualified" to perform hazardous procedures and practices.
On the second page of the certification, information about the subjects, performance exercises, and tests is described.
Sample Training Certification - Page 2
The benefit of including this second page in the document is that it can also serve as a lesson plan for your training. The learning objects you've written will help you develop the list of subjects and performance exercises. It outlines the subjects and exercises that need to be conducted to make sure required training is accomplished.
The following information was discussed with students: (check all covered subjects)
- Overview of the hazard communication program - purpose of the program
- Primary, secondary, portable, and stationary process container labeling requirements
- Discussion of the various sections of the MSDS and their location
- Emergency and Spill procedures
- Discussion of the hazards of the following chemicals to which students will be exposed
- Symptoms of overexposure
- Use/care of required personal protective equipment used with the above chemicals
- Employee accountability
The following practice/performance exercises were conducted:
- Spill procedures
- Emergency procedures
- Personal protective equipment use
The following written test was administered: (Or "Each student was asked the following questions:") (Keep these tests as attachments to the safety training plan and merely reference it here to keep this document on one sheet of paper)
- What are the labeling requirements of a secondary container? (name of chemical. and hazard warning)
- When does a container change from a portable to secondary container? (when employee loses control)
- What are the symptoms of overexposure to ___? (stinging eyes)
- Where is the "Right to Know" station (or MSDS station) located? (in the production plant)
- What PPE is required when exposed to ___? (short answer)
- How do you clean the PPE used with ___? (short answer)
- What are the emergency procedures for overexposure to ___? (short answer)
- Describe spill procedures for ___. (short answer)
- When should you report any injury to your supervisor? (immediately)
- What are the consequences? if you do not follow safe procedures with this chemical (injury, illness, discipline)
Job Hazard Analysis
Determining the content of training for employee populations at higher levels of risk like construction is similar to determining what any employee needs to know, but more emphasis is placed on the requirements of the job and the possibility of injury.
According to the text, one of the best tools for determining training content and required skills for hazardous construction job requirements is the Job Hazard Analysis described earlier. This procedure examines each step of a job, identifies existing or potential hazards, and determines the best way to perform the job in order to reduce or eliminate the hazards. Its key elements are:
- job description
- job location
- key steps (preferably in the order in which they are performed)
- tools, machines and materials used
- actual and potential safety and health hazards associated with these key job steps
- safe and healthful practices
- apparel and equipment required for each job step
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