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OSHA's new take on training means your program may not hold up
 By Fred Rine
CEO, FDRsafety
What does
your company do to make sure that employees truly understand and learn
something from safety training?
For many
companies, follow-up is limited to making sure that employees initial a sign-in
sheet and little or no effort is made to determine if learning took place. That
approach will no longer cut it with OSHA.
OSHA recently began
instructing its inspectors to issue "serious" citations if a "reasonable
person" would conclude that safety training has not been provided to employees
in a format that they are "capable of understanding." While this may mean using
a language other than English, it can include much more than that. Different
people have different learning styles for example - some respond better to the
written word, others to visuals, others need to be told things orally.
And of course, there's lots
of room for interpretation about what a "reasonable person's" judgment would
be. OSHA is not providing any guidelines.
So what's a company to do if
it does not want to get tagged?
Rod Smith, Pat Miller and Matt Morrison of the Sherman and Howard law
firm offered some suggestions in an excellent newsletter article:
- Adopt simplified safety rules and "plain English"
restatements of OSHA requirements.
- Utilize written tests, translated where
necessary, to confirm employee knowledge.
- Where reading comprehension presents an issue,
draft policies and training materials with diagrams or pictures, showing
the "right way" and the "wrong way" to perform the job.
- Verbally quiz employees with language or reading
comprehension barriers, making certain to document the determination that
the employee adequately understands the materials.
- Use a documented task evaluation that requires
employees to actually demonstrate how to safely perform a job, such as
putting on a safety harness or locking out a piece of equipment.
Contact me for more information at frine@fdrsafety.com or
(901) 573-3382.
Fred Rine has developed a safety awareness program
that motivates workers to want to act safely and use their training. The
program has been presented to more than 400,000 workers and supervisors
nationwide.
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New electrical safety standards prompt need for training, evaluation
Some
businesses are expressing concern that getting in compliance with the
new 70E
electrical safety standards developed by the National Fire Protection Association is an
extremely complicated and costly process.
There is much at stake since OSHA has begun enforcing the standards and is issuing frequent citations. But the truth is that getting up to speed on 70E is a rather straightforward process and need not be overly expensive.
Here are four key steps:
- Do a written evaluation of electrical exposures at your facility.
- Put together a written program on how to protect both "qualified" and "unqualified" workers. (An example of a qualified worker might be a licensed electrician. An unqualified worker might be a production employee who works near an electrical box.)
- Build a training program on how to deal safely with electricity at your facility.
- Provide appropriate personal protective equipment to workers who will handle electricity, based on the exposures identified in Step 1.
Some of the concern from businesses stems from fear of potentially high costs for evaluations. The fact is that evaluations can be conducted economically and involve as little as a one-day on-site inspection at a medium-sized plant.
FDRsafety can assist you with all four steps in the compliance process. Our program is led by Mike Gibson, who is an expert in OSHA - NFPA and Electrical Safe Work Practices.
For more information, contact
FDRsafety at 615-370-1730 or info@fdrsafety.com.
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OSHA targets oil and gas industry
over
flame-resistant clothing
OSHA has
ordered its inspectors to issue citations to employers who do not insure that
workers are using flame-resistant clothing where there is a potential of flash
fires - an enforcement initiative particularly relevant to the oil and gas
industry.
For more
details, see an
article by FDRsafety Vice President Jason LeMasters published in the Ohio Oil and Gas Association newsletter. We have republished it on our web site.
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Latest from our blog:
Resources on how to connect safety, 'lean' and sustainability
By Fred Rine
When you get
right down to it, safety, "lean" processes and sustainability are all about the
same thing: eliminating waste. In the case of safety, it's about eliminating
the waste of human resources through accident or illness; the other two are
about conserving financial or natural resources.
At
FDRsafety, we believe that thinking around these three ideas will continue to
converge. That is why we have established a section on our web site called "Safe, Lean, Sustainable."
In that
section, we have created a resource center where you'll find articles about the
relationship between these three concepts as well as some practical ideas about
putting them into place. The main driver behind the section is FDRsafety's
Senior Advisor, Mike Taubitz. Mike, who is former Global Director of Safety for
GM, has done lots of thinking and writing about how these ideas connect.
We invite
you to take a look at the section and also to check out a new LinkedIn group
called SHE, Sustainability and Lean, where
people interested in this topic can gather and share ideas.
Subscribe to our blog
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Visit our site!
www.FDRsafety.com
FDRsafety
278 Franklin Road
Brentwood, Tennessee 37027888-755-8010
info@FDRsafety.com
Our services include:OSHA compliance consultation Safety staffingTraining Industrial hygieneExpert witnesses
ABOUT FDRsafetyAt the heart of FDRsafety is this simple idea: Extensive expertise and experience bring the best results. FDRsafety is led by two nationally recognized, long-time leaders in safety: Fred Rine and Jim Stanley. Each has decades of experience improving occupational safety and health performance at companies of all sizes, including complex multi-billion dollar, multinational organizations. FDRsafety can meet your needs for a wide range of safety and health services, including training, OSHA compliance, safety staffing and expert witnesses. Contact us to learn how we can help you reduce accidents, meet federal, state and local legal requirements, reduce costs, and most importantly, protect your greatest assets - your employees.
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