According to sustainability reports, few things are more important than training:

• "Our associates spent more than 50,000 hours in training to assure our customers get the service they deserve." 
• "A record number of hours were devoted to training this year." 

But for every proclamation about the number of training hours, completeness percentages, or employee pass rates, we find another another spreadsheet where someone has multiplied training hours by pay rate. Even without paying for meeting space, handouts, and doughnuts, training costs are big money.

Certainly some recent outstanding developments enable training to now be provided more efficiently and economically than in the past. On-demand computer-based training allows workers to review materials any time, without the need for an expert instructor. Webinars (remotely-led meetings accessed via the Internet) enable instructors to reach trainees literally around the world, without entering an airport.

In spite of these and other developments that make training more economical, many organizations continue to ask training staff to do more with less. Too often the result can be improper rationalizations and disturbingly altered objectives:

• "We haven't changed our process and the chemicals are the same -- why should we update our training material?"
• "This computer-based training system is great -- it won't let you advance to the next item unless you click the right answer. My employees just keep clicking, and everyone always gets a perfect score."

How an organization approaches training speaks volumes about management's true expectations and indicates which goals the training will really achieve. When companies ask me to help them pick the right training path, I might need to consider the situation over an extra cup of tea before paying my bill and reaching for my fortune cookie. Recently, that strip of paper reminded me:

When the committees for ISO 14001 Environmental Management Systems and for OHSAS 18001 Occupational Health and Safety Management Systems met to consider amendments to the standards, they weren't just looking to change the title of Clause 4.4.2. They wanted to emphasize the important distinction between competency, training, and awareness.¹ 

At first, distinguishing between these three terms can be confusing. Try this example. When you board an airplane, you get a short training session (whether you need it or not) on seatbelts, flotation devices, oxygen masks, and exits. The flight attendants who provide this training are also aware of the flight's destination and have competency (skills and responsibilities) in a number of areas, such as dealing with an emergency evacuation (and even fitting luggage into overhead bins).

The difference between competency, training, and awareness sometimes gets overlooked during budget-cutting. A simple answer might be to cut everything equally: reduce the amount of time for each subject or stretch out the time between updating. But sometimes simple answers just don't cut it. I might joke with a flight attendant who mixes up the destination -- but I'm getting off if the pilot isn't competent to fly the plane.

If your training budget is getting squeezed, start by assessing your list of training subjects. What's required by regulation? What has to be repeated annually? What are nonconformances telling you about what refresher training needs? If you have to cut training time, focus on the "awareness" category. How often and how long do you need to devote to environmental aspects for employees to be "aware"? Will less time-intensive methods work instead, such as posters, articles, and videos running in the break room?

On the other hand, for skills and knowledge areas where workers need to be competent, demand adequate training. Defend the need to assure competency, and take the time and effort to verify it. A compliance audit finding I see too frequently is the failure to annually verify understanding and proper use of equipment-specific lockout procedures (see periodic inspections in 29 CFR 1910.147(c)(6)(i)). Lockout/Tagout cannot be left to individual interpretation and recollection. Employees who perform lockout (i.e., authorized employees) must not only have received training and be aware of the hazards but must also be competent in implementing the safety procedures. Another area where failing to assure competency can lead to devastating consequences is rescue operations in confined spaces (see rescue and emergency services in 29 CFR 1910.146(k)(2)). Do you want to tell a newly orphaned child that you didn't have the money to practice getting someone out of the storage tank?

Take the time to distinguish between information about which employees need to be aware, what subjects require regular training and the concepts and skills that require competency. Then your management team can focus on those training and validation areas that will make the biggest difference. (And when you've got a moment, consider the pre-flight safety presentation. You may want to add some variation into your required repeat training, or employees may tune out your instructions the same way you tuned out lifting the tab on the buckle to release.)

Curt Johnson, CPEA, is an STC Senior Program Director in Richmond, TX. He has more than 30 years experience in the development and implementation of environmental, health and safety management systems. Recent projects include assessing management systems conformance to the federal sentencing guidelines definition of an effective environmental compliance program for an offshore fleet operation and developing the management system and its documentation for a major food producer. Curt is the current author of ISO 14001: Environmental Management Systems-A Complete Implementation Guide, published by Specialty Technical Publishers of Vancouver, B.C.

To discuss this article or for more information about the ISO 14001 Guide, contact Curt at (281) 341-8289 or cjohnson@stcenv.com.