Deploy the CSMS to all work sites and carefully analyze performance.
Educate and Train
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 them first on the components of the CSMS and conduct initial instruction and training on:
manager and supervisor leadership responsibilities
train-the-trainer topics for those who will be conducting safety training
technical hands-on-how-to on-the-job training (OJT) for employees
After completing the training, make sure it is properly documented. Remember, as far as OSHA is concerned, "if it isn't in writing, it probably didn't get done." Once training is completed, it's time to officially deploy the CSMS.
To make sure the training was successful, do the following:
Get feedback from everyone on the success of the deployment.
Analyze and evaluate the quality within a year.
Make necessary improvements in training not meeting performance standards.
Orientation, Instruction, and Training
Three components of safety education: Orientation, Instruction, and OJT.
To help make sure managers, supervisors, and employees do their jobs safely, they must receive adequate:
initial safety orientation,
general instruction on OSHA standards and the company's CSMS, and
technical training on hazardous processes and procedures
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
It will 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 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;
periodic, annual (if required), and as-needed refresher training is performed; and
workers are trained on first aid and how to respond to emergencies on the worksite.
Idea: To help make sure safety training requirements are met, let employees know that completion of safety training is being entered into their performance appraisals and could affect pay raises and career advancement.
New employees should receive initial orientation that introduces them to the company's safety rules and expectations. They should also receive an overview of the hazards that can be expected on the work site.
When developing and presenting initial orientation and instruction, consider the following:
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 length and level of detail of new employee orientation, instruction, and training depend on the nature of the hazards on the worksite and OSHA requirements.
The safety coordinator or other designated site safety person will appraise the knowledge, skills, and abilities (KSAs) of exposed workers, and provide any needed on-the-job (OJT) training.
Where safety training is needed, appropriate initial hands-on how-to (OJT) training should be provided.
Records should be maintained for all new employee training sessions with descriptions of topics covered and names of workers trained.
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:
safe work practices necessary for that day’s work.
safety concerns workers may have.
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:
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, certification of training should include:
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, 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
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.
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.
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.).
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 SDS 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
The following practice/performance exercises were conducted:
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 SDS 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:
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
Construction Safety Orientation Video
This video, produced by Bird Construction, is an excellent example of a safety orientation. (Length - 18 min)
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