OSHA Steps Up Enforcement of Worker Training

OSHA’s requirement that training be comprehensible to employees is nothing new. What is new, however, is the enforcement angle. Says Secretary of Labor Hilda Solis, “OSHA compliance officers will verify not only that training has been provided, but that it was provided in a format that workers being trained can understand.”

An OSHA memorandum provides examples of what is required:

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  If an employee does not speak or comprehend English, training must be provided in a language the employee does understand.
• In the case of an employee with a limited vocabulary, the training must account for that limitation.
• If an employee is not literate, an employer will not satisfy its training obligation by telling the employee to read training materials.

“As a general matter,” says the memo, “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, they will need to provide safety and health training to employees in the same manner.”

While meeting this requirement may present difficulties and extra costs, it can also improve safety performance and reduce the risk of accidents. Employees who don’t understand safety instructions or safety training information are much more likely to have accidents and be injured on the job.

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What to Do

There are many ways you can comply with OSHA’s training requirements if you employ non-English-speaking workers or workers with limited English skills.

For employees who speak no English, use a translator to assist during training sessions. A bilingual employee could do the job, or you could hire a qualified individual from the community.

When training employees with some English, instruct trainers to:

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  Speak slowly, explain fully, and repeat important points several times.
• Choose the simplest words. If trainers need to use technical terms, they should always define them clearly and check for understanding.
• Demonstrate while they speak and use visual aids, such as pictures and props, to supplement verbal explanations.
• Encourage participation in discussions. Trainers need to be patient and help trainees express thoughts and questions.
• Have trainees practice new skills and procedures during the training session so that trainers can see that trainees have understood.
• Use feedback to confirm comprehension.
• Allow plenty of extra time for questions.
• Provide handouts in the language trainees speak and read.

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You should also be sure to follow up training on the job to make sure employees have understood and correctly applied training points.

As an extra precautions, team non-English-speaking workers with bilingual co-workers, if possible. If not, team then with willing English-speaking workers. This can both help non-English-speaking workers develop English skills and decrease the risk of accidents. This is especially important with illiterate employees who can’t read warning signs, safety instructions, and so on.

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