Implementing Safety and Health Training
Many safety and health standards promulgated by the Occupational Safety and Health Administration, or OSHA, explicitly require employers to provide safety and health training to their employees. Other OSHA standards require employers to limit certain job assignments to employees who are “certified,” “competent” or “qualified,” which means they need to have specific training—whether in or out of the workplace.
The purpose, of course, of such training is to reduce occupational injuries and illnesses and save lives. Since 1970, when Congress first passed the Occupational Safety and Health Act and established OSHA, occupational injuries and illnesses have decreased by 67 percent and workplace fatalities have decreased by 65 percent, while U.S. employment has almost doubled.
Franchisors who provide tools and training and structure safety assessment programs to measure regulatory compliance in line with the policies of their franchise systems can limit vicarious liability for the offenses of their franchisees. Bad publicity is one of the greatest fears of any franchisor in part because it can produce a multiplier effect from a single adverse event. With the advent of the Internet, e-learning, with the use of a learning management system, has proven to be a cost-effective and flexible method for deploying critical training and knowledge-based information as a preventive initiative to not only mitigate risk and negative publicity, but also to strengthen internal brand communications.
Despite good intentions to comply with OSHA training requirements, franchises can have difficulties doing so. Some challenges include identifying the training subjects required and determining who needs training, in what subjects and how often. Because of the variety of training requirements and logistical problems, administering safety and health training has always constituted a major impediment for many franchises. The following steps explain how to identify applicable safety and health training requirements and how to implement a training and recordkeeping solution.
Step 1: Identify Which Requirements Apply
Meeting federal OSHA requirements is not always sufficient. Because all U.S. states and territories have the option either to participate in the federal OSHA system or to create their own state OSHA programs, each state has different requirements. Some states, like Tennessee, have a hybrid approach in which a state OSHA program has jurisdiction over general industry and construction, but federal OSHA retains jurisdiction over the maritime industry. Some state OSHA programs have standards similar to the federal OSHA system, and some have slightly different standards, while yet others have significantly different standards, such as California’s Cal-OSHA and Michigan’s MI-OSHA.
Therefore, the first step employers, safety and health professionals, and training and human resources departments need to take is to understand state requirements. OSHA’s website (http://www.osha.gov/dcsp/osp/states_posters.html) provides a full list of state OSHA posters, which can be a starting point for learning about state OSHA requirements.
Sometimes fulfilling state and federal OSHA requirements is still not enough. If an employer recognizes a hazard that training would mitigate, the employer must protect its employees by developing safeguards and providing the necessary training, regardless of whether an OSHA standard exists for that particular hazard or not.
Step 2: Identify Which Industry Standards Apply
Industries are not equal when it comes to health and safety training. OSHA training requirements can be industry-specific, workplace-specific and or hazard-specific. Industry-specific training requirements exist for:
- General industry
- Maritime industry
- Construction industry
- Federal government
More information about the training requirements for these industries is available at the OSHA website (http://www.osha.gov/Publications/2254.html).
In addition, certain industries, such as mining, are covered by entirely different regulatory agencies. Furthermore, in some work situations, non-OSHA regulations take precedence over OSHA’s; these include workers on a ship at sea, flight crews on an airplane and truck drivers on the highway.
The key is to identify actual or potential workplace safety and health hazards and to provide safeguards against them. OSHA requires companies to provide training in hazard recognition, safeguarding techniques and use of special equipment or procedures based on exposure or the expected likelihood of exposure to work-related hazards. Required training subjects derive from a company’s review and assessment of potential hazards for all aspects of company operations, including facilities, equipment, purchased products, materials used, work procedures, processes, finished products, byproducts and exposure through independent contractors that can affect company employees.
Step 3: Provide Appropriate Safety and Health Training
A misconception exists that small franchises are exempt from providing occupational health and safety training. This is not true. All employers, regardless of size, must comply with OSHA rules and regulations. Although OSHA typically doesn’t conduct inspections in companies with fewer than 10 employees, such companies are still subject to inspection when an employee files a complaint or a workplace fatality occurs.
Some exceptions exist. For example, in some cases, small businesses may be exempt from implementing specific OSHA standards, like those requiring an OSHA injury/illness log or a written emergency action plan. Furthermore, sole proprietors and family members working on a family farm are not subject to OSHA standards.
Employers must provide training at several points in an employee’s career, such as during new employee orientation, when an employee or contractor is newly assigned to a job where specific hazards exist, and when the hazards of a specific job change. Some types of safety and health training must be repeated periodically.
Although some regard safety and health training as a waste of money and time, training in the proper performance of a job is time and money well spent. An effective safety and health training program can result in fewer injuries and illnesses, better morale and lower insurance premiums.
Step 4: Determine How to Deliver Training
When the required training subjects have been identified, the employer must decide how to get the required training materials and how to deliver them. Developing materials can be expensive because it entails hiring qualified personnel to create them and keep them up to date, while purchasing materials requires the employer to evaluate the materials carefully.
Another consideration is the delivery method. The most common options are instructor-led classroom training and e-learning. Although instructor-led classroom training can have many benefits, the costs of qualified trainers, of time away from the job for participants and for facilities add up quickly. Furthermore, instructor-led, classroom training is not always consistent among different training classes and takes a long time to update, which can be a problem when new hazards are identified or OSHA requirements are updated.
E-learning is an easy, flexible and cost-effective alternative for providing safety and health training, providing these benefits:
- Saves money on consultants, travel, lodging, facility, printing and time away from work.
- Minimizes disruption to normal business activities.
- Reduces training time by up to 50 percent.
- Allows learners to train at their own pace.
- Provides continuous access.
- Can be scheduled during intermittent slack periods.
- Enables access from any location with an Internet connection.
- Delivers consistent content to all learners.
- Allows quick and easy modification.
Step 5: Keep Training Records
Employers must keep records of all safety and health training because such records provide evidence of compliance with OSHA standards. Furthermore, documentation provides answers to the first question an accident investigator asks in case of a workplace accident: “Was the employee trained to do the job?”
One effective way to keep track of safety and health training compliance is to deploy a learning management system to deliver e-learning and provide tracking and reporting features, thus streamlining training administration. A learning management system can provide fast, easy and accurate access to training records, which is particularly helpful when attempting to substantiate training compliance in the event of an inspection by federal or state compliance officers. ⎯
Dale Haskin is an OSHA subject matter expert for Vivid Learning Systems, a leading e-learning safety solutions provider. He can be reached at firstname.lastname@example.org.