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However, the Occupational Safety and Health Administration (OSHA) says that an employer’s responsibility to provide employees with information and training about safety and health hazards doesn’t go away because an employee can’t understand standard English-language training programs. When that is the case, employers must inform and train these workers in a language they can understand.
“As a 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, they will also need to provide training to employees in the same manner,” says OSHA.
Serious Training Violations
OSHA’s training provisions contain a variety of specific requirements to ensure that employees are comprehending instruction. For example, standards covering lockout/tagout, respiratory protection, and bloodborne pathogens each require that employers take measures to ascertain the level to which the employee has comprehended the safety provisions.
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In its instructions to inspectors, OSHA states, “If a reasonable person would conclude that the employer had not conveyed the training to its employees in a manner they were capable of understanding, then the violation may be cited as serious.”
Enhancing Comprehension
Although Spanish is the most common second language spoken in the United States, there are many other languages ESL workers might speak, including:
- Chinese
- Arabic
- Vietnamese and Cambodian
- Various African languages
- Portuguese
- French
Take these steps to make sure your training message is understood by ESL workers.
- Speak slowly, explain fully, and repeat important points several times.
- Choose the simplest words and avoid technical jargon. If you must use technical terms, explain them in simple terms.
- Use a translator if appropriate.
- Demonstrate while you speak, and use visual aids, such as pictures and props, to supplement your words.
- Encourage participation. Be patient and help employees express their thoughts and questions.
- Have employees practice new skills during the training session so that you can see if they’ve understood.
- Use feedback to confirm comprehension. Allow extra time for questions.
- Provide handouts in the language(s) trainees speak and read.
- Follow up on the job to make sure that employees correctly apply what they learned.
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The language barrier may be only part of the problem when training ESL workers.
Cultural differences can also affect communication. In many foreign cultures, for example, older people are treated with great respect and deference, whereas in the more casual North American culture, older people might be treated with more familiarity. For example, older Hispanic workers might be offended if they are addressed by their first name, preferring to be called "Señor" or "Señora."
Updated Guidance from OSHA
In August 2015, OSHA posted a fully updated version of its guide to all OSHA training requirements. The document, Training Requirements in OSHA Standards, organizes the training requirements into five categories: General Industry, Maritime, Construction, Agriculture, and Federal Employee Programs.
For more help understanding OSHA’s training requirements, check out
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