The Best-Laid Plans

For example, the General Housekeeping Standard (29 CFR 1910.22) says that “all places of employment” must be kept “clean and neat,” and describes what that means. It doesn’t require that employees be trained in the standard, but it would be difficult to meet its requirements without: (a) advising employees of the existence of the standard, and (b) training them in how to comply with it.

Broad requirements like hazard communication, PPE assessment, and, certainly, the General Duty Clause, put much responsibility on management to identify training needs without simply relying on rules. Other more specific requirements, like lockout/tagout and confined spaces, have detailed requirements must be followed.

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Finding the areas where training is needed is only the first step. Next, you must do the following:

• Set priorities. Pay attention to those areas that pose the greatest threats first.

Which issues apply to your workplace or work area?

• Are there hazards that could result in death or serious illness or injury?
• Are there conditions that could have major environmental impact if an accident occurred?
• Are there conditions in which an accident could cause a serious loss to your company?
• Are there operations or procedures where you’ve had a pattern of repeated accidents or near misses?

These are the areas you must address first, even if not all employees need to be trained.

• Then, determine the who, what, when, where, and how. Organize training around the question, “Who needs to know what and when?”
• Devise a system for combining coverage of “perennial topics” for all employees, with specific training for various subsets of employees.
• Create a planning grid to plan training by job, function, area of responsibility, or department.
• Also put together a training calendar to organize your training needs alongside seasonal and special “awareness” dates, such as National Safety Month in June.

When assessing training needs, don’t forget that training may not be the best answer to problems or hazards you identify. Ask if the problem could be solved in some other way, including:

• Changing the type of equipment
• Changing the procedure
• New engineering controls (e.g., guards, ventilation fans)
• Increasing supervision or modifying how the supervision is done
• Getting more cooperation from employees

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Why It Matters

• More than 70 percent of employers provide training for employees.
• Safety training for new employees is imperative.
• Refresher training is also important to avoid complacency.
• Training after near misses is also a vital step toward preventing an accident.

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