Step 1: Know Which Agency Rules Apply
The U.S. Environmental Protection Agency (EPA), OSHA, and the U.S. Department of Transportation’s Pipeline and Hazardous Materials Safety Administration (PHMSA) each have separate training rules, but there is often overlap among the various training requirements.
For example, an employer may have workers managing hazardous waste and have the same workers preparing hazardous materials for transportation. In this situation, EPA’s hazardous waste rules, OSHA’s Hazardous Waste Operations and Emergency Response (HAZWOPER) requirements, and PHMSA’s hazardous materials training standards would all apply.
Therefore, it is important to be familiar with each agency’s training rules. In some cases, OSHA and the EPA have separate training requirements for the same operation, process, or substance. It can be difficult to determine which rule applies in a specific situation.
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Step 2: Determine Appropriate Delivery Method
There are advantages and disadvantages to various training delivery methods and formats (e.g., classroom, slide show, computer, hands-on) and learning aids (e.g., videos and handouts). Given the multitude of training requirements that a company or facility manager must address, it is best to review available training delivery methods and tools rather than to rely on a “one-method-fits-all” program.
The delivery of well-designed computer or Internet-based training can, in some cases, offer dramatic cost savings. EHS managers, however, must also consider the effectiveness of this type of training in meeting employee performance objectives. Cheaper training doesn’t necessarily translate to better training or regulatory compliance.
In addition, many EHS managers wonder how effective computer-based training (CBT) is and/or how regulatory agencies view the effectiveness of CBT.
When considering CBT programs, there are certain considerations to keep in mind:
- The employer, not the training provider, is ultimately responsible for ensuring that employees receive the proper training to perform their duties.
- Use of computer or Internet-based training by itself would not be sufficient to meet the intent of most OSHA training requirements, in particular those of HAZWOPER. Employers may use the CBT programs to meet the minimum requirements for the course content material of a training course.
- In many cases, OSHA requires that trainees have the opportunity to ask questions in order for training to be effective—a telephone hotline or e-mail satisfies OSHA’s requirement for trainer access if the employee can ask and receive a response from a qualified trainer.
- It is possible, in some cases, to use CBT to meet the 8-hour HAZWOPER annual refresher training requirements (29 CFR 1910.120(e)(8)), provided the training is supplemented by auditing the hands-on performance of work tasks.
- Employers that use CBT must still meet the minimum duration and type of hands-on or supervised training specified in OSHA requirements.
- Although PHMSA does not specify delivery methods or formats, it would be difficult in many cases to demonstrate the effectiveness of PHMSA’s requirement for “function-specific” training without at least some hands-on training.
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Step 3: Ensure that Workers Understand Training
It seems intuitive that training be conducted in a manner that the employee can understand. However, in a rush to get training “done” and save on costs, many employers bypass this requirement.
It would make sense, and is at least OSHA’s general policy, that if an employee receives job instructions in a language other than English, training and information must also be conveyed in that language. Similarly, if the employee’s vocabulary is limited, the training must account for that limitation. Furthermore, if employees are not literate, telling them to read training materials will not satisfy the employer’s training obligation.
“In the Field and on the Floor”
Remember, the real tests of your employee training program come “in the field and on the floor.” At the very least, if your employees cannot demonstrate proficiency in their training to agency inspectors, you are likely looking at a citation.
If there is an accident and an employee is injured, your safety training program will be under scrutiny.
If there is a spill or unpermitted release to the environment, the EPA is sure to focus on whether the workers involved had the proper training to prevent the accident and or at least mitigate any environmental damage.
If your driver is in an accident and/or there is a release of hazardous materials, you have got to know that PHMSA will be looking at your training records.