Update from our Safety Director
OSHA TRAINING STANDARDS POLICY STATEMENT
The purpose of this article is to reiterate Oregon OSHA's policy that employees training required by OSHA standards must be presented in a manner that employees can understand.
Employers Training Obligation
Many Oregon OSHA standards require that employees receive training so that work will be performed in a safe and healthful manner. It is the OSHA's position that, regardless of the precise regulatory language, the terms "train" and "instruct," as well as other synonyms, mean to present information in a manner that employees receiving it are capable of understanding. This follows from both the purpose of the standards - providing employees with information that will allow work to be performed in a safe and healthful manner that complies with OSHA requirements and the basic definition of training and instruction.
� Training and instruction mean imparting information, a definition that implies the information is presented in a manner the recipient is capable of understanding.
Oregon OSHA has a long and consistent history of interpreting its standards and other requirements to require employers to present information in a manner that their employees can understand.
� Instruction that employers must provide must be tailored to the employee's language and education and learning style, whether it's: 1) Auditory - speaking and hearing/listening; 2) Visual - sight; and 3) Kinesthetic - hands-on.
� If the employees receive job instructions in a language other than English, then training and information to be conveyed will also need to be conducted in a foreign language.
In practical terms, this means that an employer must instruct its employees using both a language and vocabulary that
the employees can understand.
� For example: If an employee's vocabulary is limited, whether they comprehend the English language or not, the training must account for the limitation.
� By the same token, if employees are not literate, telling them to read training materials will not satisfy the employer's training obligation. As general matter, employers are expected to realize that if they customarily need to communicate work instructions or other workplace information to employees at a certain vocabulary level or in a language other than English. Employers will also need to provide safety and health training to employees in the same manner.
Additionally, Oregon OSHA's training provisions contain a variety of specific requirements related to employee's comprehension.
� For example: Lockout/Tagout requires the employer to verify that the employees have "acquired" the knowledge and skills which they have been trained.
� The Respiratory Protection standard requires retraining when "inadequacies in the employee's knowledge or use of the respirator indicate that the employee has not retained the requisite understanding or skill".
Oregon OSHA Enforcement
Oregon OSHA's Safety and/or Health Compliance Officers have a responsibility to check and verify that employers have provided training to employees in a format that the employees being trained could understand.
The compliance officer is to determine whether the training provided by the employer meets the requirements and intent of the specific standard, considering the language of the standard and all of the facts and circumstances of the particular workplace.
� For example: The compliance officer emphasis is to look to whether workplace instructions regarding job duties are presented in a manner that employees are capable of understanding and whether the employer already is transmitting information with comprehensibility in mind.
� Note: Compliance officers may look beyond any basic paper documentation; i.e., an employer may have training records but employees may not have been able to understand the elements included in the training.
Please contact Selectemp's safety department for additional information or if you would like assistance with auditing your current training methods to ensure that employees receive training so that work will be performed in a safe and healthful manner.