The following is an excerpt from our on demand webcast, Troubleshoot Your Training—Live!, hosted by Chief Safety Officer Jill James and Dr. Todd Loushine.
Dr. Todd Loushine:
I know everybody gets really hyper about training and a lot of the questions revolve around it which is great. I reviewed a lot of really bad training. I'm even given a lot of bad training. Here's the thing. You got to go do your homework first. You can't just go, "Oh, I got to do respiratory protection training tomorrow. You know what, I'll just read them 19-10-134." No, that's not what they need. You give them just what they need. Okay, this line here, because we did air sampling and they're close to the PEL, we're going to require them to wear dust mask. It's an half face air purifying respirator. Now, what did they need to know? Just to use this and still get their job done and maybe they have some questions like, "You know what, it's hunting season. I'm growing a beard so either you're going to fire me or I'm not wearing this half face." Well, can we get them a hopper, can we get them a hood?
You don't want to make any decisions until you truly understand what you're trying to accomplish and that you couldn't eliminate it so therefore we have to provide the elements of the control or to reduce exposure. So again, we couldn't eliminate it so therefore we just have to tell them what they need to know but we have to talk to them first to understand what that is. So anybody who's ever tried to manage a safety program just from the office can't do it. It's not real. It's not authentic. That's why workers maybe kind of checking out when it comes to your training.
Let's see, the next thing I want to talk about is it's good to try to include the workers in developing the training or involving them. I'm not talking about doing like a role play but the closer you can get the training to the actual work, the easier it is going to be for them to use it and recall it and understand it. You need to have an annual plan and you should have an annual plan and you should have make up dates for people who couldn't just make it on that particular day. You have a list of the workers who need certain types of training and there should be some sort of either demonstration test, something to show that they've learned it or that they've acquired the knowledge you need them to have.
So unfortunately, you should have learning objectives or session learning objectives that you're going to be then testing them on. You also need to keep a summary or an outline of what you're going to be training them which is another part of this development. You should have the qualifications for the instructor or the trainer. I mean, if I was asked to train on something that I'm not an expert about, maybe that's fine if I could hire someone to come in and do it for me who has the expertise and then I can fill them in on the location information so it can be very specific. But you establish the trainings and dates, and here are the workers that need it and then their scores become the tracking mechanism.
They have to score 80% or greater, 90% or greater. You set your limit. It's the percentages that you show and it would be interesting over time that as the tests and demonstrations get more rigorous, you can challenge workers to score higher on their performance or test, that's a great leading indicator that things should be getting better. They understand what they need to do from a safety perspective for that particular element of the program to keep themselves and their coworkers safe. Jill?
Yeah, sure. So I think I always start with answering the question for the person who's taking the training, what's in it for them. So what is in it for them, why do they need to pay attention, how do we make this personal? With regard to safety, it's like, we can say, "Hey, that's a violation of a regulation," but what does that teach anyone? So it's this is wrong and here's why, here's what can happen to you if we don't wear that respirator, if we're lacking machine guarding, if we're having an electrical hazard and this is what the hazard is and this is what can happen to you adversely. Here's the right way, the way we want you to do things, here's the correct way to fix something or a way to do it so people understand really what's in it for them and that their life, their limb, their health is on the line and that the reason for the training is you're making it personal for them so they can feel that on their own personal level and kind of approaching it that way.
Then to back up, of course there are the OSHA regulations, talk about the bare minimum things we have to cover and those are listed in each regulation under each topic of the things that employees have to be trained on and so you don't want to just go to YouTube and find a video that talks about whatever and say that's the training. You've shared the information that you have to under the law with the employee but frame it in a what's in it for them way. Of course, I'm partial to online training because I used it for employees and I work for an online training company and so the methodology that's used is to engage workers in that manner and to use various interactive means and methods to engage people to be testing those skills along the way so that they're paying attention and that you have a way to assess knowledge transfer in an adult learner.
Then as far as documentation goes, Todd talked about some methods to use. I'm partial to learning management systems that track training that people have taken and that set up recurring dates for training so that you're not missing anyone, so that you have reminders on this person was away on vacation or we missed this person or we needed to onboard this person. You have those reminders so you're not tracking them in a manual way. I guess, Todd and I, I think I can speak for both of us, in the years that we worked for OSHA, training documentation is something that we reviewed every single inspection. That's what we ask for. That's what we expected employers to provide us.
So sometimes, we're maybe cherry picking and saying we want to see the training documentation for this whole department on this particular subject or all of these subjects and we want it for the last year, we want it for the last three years, or we're going to go through a certain number of employees that we interviewed today and we want to see their training record history. When we got those records, the thing that we didn't want to see was a piece of paper that had somebody's name printed and then a signature next to it with forklift training over the top of the form. That wasn't adequate for documentation.
As Todd pointed out, we wanted to know what learning objectives were, what was shared with those employees and who did the training. So tracking things on paper is fine but if you can't prove up that you minimally met compliance with the OSHA laws and who did the training and what was discussed, you don't have a very good training document.
One thing everybody should be writing down here is from an OSHA perspective, if it's not documented, it didn't occur and that's very true.
The four D's. Didn't document, didn't do is the assumption.