Page 44 - OHS, June 2022

TRAINING: SOFTWARE
can help ensure your training program is effective, compliant and top of mind.
Training and Why It Matters
Training is so critical because it is the most direct way to engage workers with your EHS programs and in your workplace EHS culture. It’s how your employees learn to do their jobs safely, effectively and in accordance with regulatory rules, guidelines and standards. It’s how you make sure that your EHS programs and policies are reflected in the day-to-day work your employees perform. It’s also one of the best ways to gather feedback from your people about what issues they are encountering, what constraints they feel and where gaps exist between intentions and reality.
OSHA and other regulatory agencies also require training. While the General Duty Clause of the 1970 Occupational Safety and Health Act simply states that employers must provide, “Employment and a place of employment which are free from recognized hazards that are causing or are likely to cause death or serious physical harm,” training plays an important role in helping employers to meet their obligations. Additionally, many OSHA standards lay out explicit requirements for training and measurements of training efficacy, as summarized in OSHA’s guidance document Training Requirements in OSHA Standards.1 Similarly, you may find that specialized training is required for certain groups of employees depending on their job functions and applicable regulations. For instance, a forklift driver must be trained in the proper operation and maintenance of a forklift, according to OSHA’s Powered Industrial Trucks Standard.
The timing of EHS training also matters. People need to know how to do their jobs safely before they start working onanewtaskorinanewareaofthe facility. People also need to know what to do if an incident or accident happens. Some regulations establish specific timing requirements for training. For instance, the Hazard Communication (HazCom) Standard requires employers to train all workers about chemical hazards and key elements of the employer’s HazCom program such the method of providing access to safety data sheets (SDSs) and must provide this training at the time of
their initial job assignment, and whenever a new chemical hazard the employees have not previously been trained about is introduced into their work area. Employers who fail to provide proper training when they need to provide it not only are out of compliance with HazCom requirements but also create risks for their employees and their business.
Beyond training on specific tasks, employers should also pay attention to the environmental conditions where the work takes place. Are employees exposed to potential hazards that require additional monitoring or precautions, such as gauges or meters? Your training should reflect that. Keep in mind, too, that training requirements may vary based on location, with certain states having their own, often more stringent training requirements in specific regulatory areas.
How Online
Training Software Can Help
Even when employers understand the importance of training, they often struggle to do it right, make it a priority or properly resource it. Additional headwinds come in the form of shifting regulations, changing processes and policies, new facilities and equipment, and an evolving workforce.
In short, training needs are constantly changing, and as the EHS professional in charge, you must stay agile and keep finding time to address these challenges head on.
Let’s look at the two areas where safety professionals often have training challenges—training cadence and training temporary workers—and ways training software can help.
Training has a way of becoming fossilized, with many companies falling into an “annual training” mindset with their training programs. Once a year they dust off their training materials and go through the motions of walking the workforce again through the same things they covered the year before. This “annual training” mindset makes it easy to neglect needed training updates, puts employees at risk and takes your company out of compliance with important training requirements. OSHA rarely specifies training frequency requirements outside of certain, specific regulations; instead, OSHA requires training whenever it is necessary for the health and wellbeing of workers. Actions that can trigger training responsibilities include the introduction of new chemical hazards into the workplace, the introduction of new machines,
38 Occupational Health & Safety | JUNE 2022
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