Heat illness, Training

How’s Your Training Program?

Do you have a strong employee safety training program?

While training alone is not enough to prevent workplace injuries and illnesses, it remains a key element of an effective safety and health management program. Research has shown that education and training can increase workers’ knowledge and help guide their actions and behaviors on the job.

Therefore, your workers need to understand the health and safety hazards inherent to their jobs and how to identify them, as well as the hazard controls in place to protect them. If any work necessitates the use of personal protective equipment (PPE), your workers need to know how to wear and use it properly.

If you employ young seasonal workers, they may have little to no knowledge of health and safety hazards on the job and will need training before being assigned any on-the-job tasks.  

Nearly every Occupational Safety and Health Administration (OSHA) construction, general industry, marine terminal, and maritime standard contains a training requirement. Some training requirements are extensive enough to warrant a separate standard. While the construction industry fall protection standard (29 Code of Federal Regulations (CFR) §1926.501) is OSHA’s most frequently cited standard, the fall protection training requirements standard (§1926.503) is also one of the agency’s most frequently cited standards, cited 1,666 times in fiscal year (FY) 2021.

There also are separate training standards for confined spaces (§1926.1207), cranes and derricks (§1926.1430), electrical safety-related work practices (§1910.332), scaffolds (§1926.454), shipyard fire protection (§1915.508), stairways and ladders (§1926.1060), and steel erection (§1926.761), as well as a general construction industry safety training and education standard (§1926.21).

OSHA emphasizes safety training in both its enforcement and compliance assistance efforts, and the agency’s training outreach programs include worker and supervisor training. The OSHA 10-hour training program is intended for entry-level workers, and the 30-hour program is intended for employees with some safety responsibilities. Industry-specific training (construction, disaster site, general industry, maritime industry) is provided by OSHA-authorized, third-party trainers. Once workers or supervisors complete training, trainers provide them with 10-hour or 30-hour cards.

The outreach training program covers the recognition, avoidance, abatement, and prevention of workplace hazards. Outreach classes also include an overview of OSHA and worker protections under the Occupational Safety and Health Act and the agency’s standards. Training covers workers’ rights, employer responsibilities, and how to file a complaint.

The outreach training program has continued to grow since it began in 1971. More than 5.21 million workers were trained in the recognition and avoidance of job hazards through the program between FY 2016 and FY 2020.

Heat stress

On April 13, OSHA unveiled its heat-related hazards national emphasis program (NEP). The program’s inspection procedures include questions about employee training. During a heat-related site or facility inspection, agency compliance safety and health officers (CSHOs) investigate employee training on heat illness signs, prevention, and the importance of hydration; how employees are instructed to report signs and symptoms; and procedures for first aid and contacting emergency personnel.

Even before issuing the NEP this spring, OSHA cited employers for training deficiencies following heat-related fatalities. In January, OSHA cited a Florida employer for safety and health violations following a heat-related death. Citations included failure to train at least one crew member to perform first aid who is available to render assistance in heat-related emergencies.

OSHA also is developing a federal heat injury and illness prevention standard that could apply to both indoor and outdoor work settings. A standard would likely include training requirements. The agency asked stakeholders about worker training and engagement in its October 27, 2021, advance notice of proposed rulemaking.

The National Institute for Occupational Safety and Health (NIOSH) also included recommendations for training requirements in its 2016 “Criteria for a Recommended Standard: Occupational Exposure to Heat and Hot Environments” (DHHS (NIOSH) Publication No. 2016-106).

NIOSH recommended that training requirements include coverage of:

  • Heat stress hazards and potential health effects of excessive heat stress;
  • Predisposing factors and the effects of therapeutic drugs, over-the-counter medications, alcohol, or caffeine that may increase the risk of heat injury or illness by reducing heat tolerance;
  • Signs and symptoms of heat injury and illness, as well as workers’ responsibilities for following proper work practices and control procedures to help protect their own health and the health and safety of their fellow employees, including instructions to immediately report to the supervisor the development of signs or symptoms of heat-related illnesses;
  • Proper precautions for work in heat-stress areas, general first aid, and worksite-specific first-aid procedures;
  • Cultural attitudes toward heat stress, such as the misperception that someone can be “hardened” against the requirement for fluids when exposed to heat by deliberately becoming dehydrated before work—a dangerous misperception that must be corrected with worker education and training;
  • Descriptions of environmental and medical monitoring elements of a heat illness prevention program, the purposes of such surveillance programs, and the advantages to worker participation in surveillance programs; and
  • Proper use of any heat-mitigating protective clothing and equipment.

NIOSH recommended that training be conducted by persons qualified in occupational safety and health by experience or training to ensure that workers potentially exposed to heat stress and their supervisors have current knowledge of hazards and controls and how to respond to heat illness emergencies. NIOSH also suggested that employers make any written training materials readily available to workers. Any written training plan also should include a record of all instructional materials.

Fall protection

As mentioned above, OSHA’s construction industry fall protection training standard remains one of its most frequently cited year after year.

OSHA recently concluded another National Safety Stand-Down to Prevent Falls in Construction.

Research from the American Society of Safety Professionals (ASSP) has found that inadequate training and worker lack of knowledge are factors in falls and other injuries among young immigrant construction workers. The ASSP and NIOSH recommend culturally tailored training programs to prevent falls among such workers.

Regardless of the makeup of your workforce, your training program needs to be geared toward the intended audience, taking employees’ cultural and educational backgrounds into consideration, including literacy levels. In some circumstances, training may need to be delivered in a language other than English.

Fall protection training must cover the nature of fall hazards in the work area, as well as the correct procedures for erecting, maintaining, disassembling, inspecting, and using fall protection systems like guardrail systems, personal fall arrest systems, safety net systems, warning line systems, and safety monitoring systems.

Training also must cover the correct procedures for the handling and storage of equipment and materials to prevent struck-by hazards. Workers also must be instructed in the limitations of mechanical equipment while performing roofing work on low-sloped roofs. All employees must be instructed in their responsibility for monitoring safety when fall protection systems are in use.

Training must be performed by a “competent” person who is well aware of fall protection measures and site-specific systems.

If you are a construction employer, you must keep written records certifying your workers’ fall protection training, tracking employee names, dates of training, and trainers’ signatures. Additionally, you must retrain workers whenever there are changes in the equipment or systems used for fall protection.

Training challenges

Challenges in safety training include the training of young workers and workers at multiemployer facilities and sites.

Young, seasonal workers can find themselves in hazardous work situations without adequate safety and health training. The American Industrial Hygiene Association (AIHA) has suggested that occupational safety and health training in schools could help protect young workers, and the group would like to see state and local governments require a workplace safety curriculum in schools for grades 7 through 12. However, if you employ young workers, you are responsible for training them in the safety and health hazards on the job and appropriate precautions.

OSHA addressed young worker health and safety last fall before the holiday shopping season.

“All workers–from those starting their first job to those making some extra money as a seasonal worker to those year-round employees–are entitled to a workplace free from hazards and to be trained in a language they understand to recognize and prevent hazards,” Assistant Secretary of Labor for Safety and Health Doug Parker said at the time.

Are you responsible for contract employees’ safety and health training? Yes. OSHA can and does cite both host employers and staffing agencies for deficiencies in worker education and training.

For example, during an inspection for compliance with the hazard communication standard (1910.1200), agency inspectors will interview employees at a multiemployer facility or site to check whether they all understand how to read a hazardous chemical label and know where and how to access safety data sheets for the chemicals on-site.

While OSHA didn’t cite any violations following fatal and severe injuries when a December 10, 2021, tornado struck Amazon’s Edwardsville, Illinois, warehouse, the agency did issue hazard alert letters to Amazon and several of its logistics contractors.

OSHA urged Amazon and its contractors to ensure that all employees are provided training in responding to severe weather emergencies and participate in emergency weather drills.

Is training effective?

How effective is training? The evidence may be hazy, but worker training remains a key part of safety and health management.

In 2010, NIOSH put out a systematic review of the effectiveness of education and training in protecting worker health and safety.

The institute found evidence to support the need for training and urged employers to continue worker safety and health training. NIOSH researchers found that employee education and training are effective in shaping workers’ knowledge and attitudes. However, it found no evidence of the impact of training alone in reducing injuries and illnesses.

NIOSH concluded that more research on training effectiveness is needed, and the review team could not make any recommendations about the nature of training, such as computer-based versus in-person instruction, the level of engagement, or the optimal number of training sessions.

While training alone isn’t enough to protect your employees’ health and safety, training can be an effective method of communicating your company’s safety culture.

It may be worth reviewing your training program to ensure it covers the training requirements of all the standards that apply to your facility or site. Your employees also may need general safety training to fill any gaps in their safety knowledge.

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