I had the question asked of me one day, “When should a company provide the OSHA required safety training?” I asked a friend of mine who works at one of the Atlanta OSHA field offices and his answer was “before they have an exposure or incident that could result in injury or illness”. That is regardless of past training from other companies without current company competence demonstration. Hiring employees trained by other companies and without a documented competency demonstration is not acceptable. Part time employees as well as Contract Employees that receive direct supervision from the company require the same training as full time employees if exposures are equal. Independent contractors are responsible for their own training.
I hear stories all the time about companies that just refuse to provide required training in a timely fashion. Training must occur also when standards or work rules change, i.e. PPE requirements in February 2008, Crane and Derrick Standards in November 2010. Many times, employees are hired and put to work immediately before any safety orientation, training, or updated required compliance training has been provided. I recently spoke to a Safety and Health Advisor at a company that was attempting to convince the owner of a company to update training with a OSHA 30 hour class. The owner replied that “our employees had training in 1978 and we are not taking the time to train anymore”. This type of understanding will eventually result in employee injury or illness, and possibly following with an OSHA investigation. At that point, reality will occur. Sadly, it will be too late for the employee(s) and the owner. Many times, employees walk in the door with training from other companies and the new employer assumes this is adequate to satisfy OSHA requirements.
Let’s take a look at what OSHA expects when a company hires an employee. If the new employee comes into a company with absolutely no required safety training, there should be no doubt about what the employer should do. Any task related to job the new employee is expected to perform or any environment the employee will be exposed to, the employee must be trained in hazard recognition, PPE and any other performance or consensus standard related to work activity. In the electric utility world, all is outlined in OSHA Performance Standard 29 CFR 1910.269, but there are many other voluntary consensus standards that apply to work practices and procedures. There really is no accepted time period to provide the training before an illness or injury occurs. Training records will be the first documentation requested by an OSHA investigation. If they are inadequate or incomplete, the company will most likely be cited for failure to provide the training and possibly for a 5A1 General Duty clause violation.
The next question that arises is a company hiring an “experienced” employee that has been “qualified” by training at another company can just go straight to work and the company is “in compliance” with standards. In the electric utility world, 29 CFR 1910.269(a) states qualifications are required to be documented by a company before the employee is to be “qualified” to work around energized and exposed conductors or equipment. The question is, “does the training the employee received by former employer qualify the employee?” The answer is “Yes” if the new employer confirms competencies by observation and proper documentation. An OSHA 10 or OSHA 30 T&D General Industry card confirms classroom training. Nonetheless, competency must be confirmed by new employer by observations and then documented. An American Heart Association or American Red Cross card confirms the required CPR and First Aid courses that are needed to be qualified employee must be “current” not two or three years old. Powered Industrial Truck training required fewer than 29 CFR 1910.178 is difficult to confirm and in many cases, the employee should be retrained if the new company expects employee to operate a PIT. Similar type of equipment also can be a problem. There are several types and classes and the employee should be proficient in the type and class they are to operate. If they operate more than one type and class, all should be documented in their training records.
Industrial Hygiene topics such as Hazard Communication, Hazardous Materials, Hearing Protection, and RF Awareness are often provided by contractors, not by safety and training employees, but are just as important. Haz Com, Haz Mat issues should not be accepted without retraining and documentation by new employer. No two companies are exactly alike with the exact same hazards.
Federal Highway Administration DOT/CDL rules require documentation of Federal Motor Carrier Safety Regulations training before employees drive Commercial Motor Vehicles. A Driver Qualification File must be complete with all documentation by the new employer or they risk liability and citations. A CDL license only means they have passed a written and practical test and were successful. A Driver Qualification File is what “qualifies” the driver to drive a company’s vehicles.
In Summary, the employee training is required by the company under the OSHA and other governing agencies. However, that is only the first step for a successful and productive employee. Training is continuous improvement and developmental for all employees. It is not a onetime application to be completed for compliance requirements. Employees are a company’s most valuable resource.
As I have said many times, “If you think you know it all, get someone to check your pulse, you may not have one.”
Until next time, stay safe out there.