Really Effective Training

HazCom training is oft delivered, oft cited, and oft maligned--all from a lack of good adult learning principles.

HOW does the theory of adult education fit into Hazard Communication training? What truly is "effective training" as required by OSHA? Does HazCom training have to be boring? How can it be improved from an adult learning perspective? In this article I will try to answer these and other related questions. As background to our quest for improved HazCom training, let's take a look back--albeit a brief one--at chemical hygiene and safety training.

Ever since chemical use in the workplace began, some type of chemical hygiene and safety training has undoubtedly taken place. Perhaps the second worker ever was warned not to "imbibe" a certain chemical "brew" lest he die from it (as befell his predecessor).

Any history of chemical safety training would be remiss if it did not mention some of the earliest industrial hygienists (IHs). Paracelsus, Ramazinni, Agricola, and the Plinys (the Elder and the Younger) all contributed to knowledge of chemical hygiene and its training. Without Paracelsus, we wouldn't have the saying, "the dose makes the poison." Where would occupational medicine and IH be without Ramazinni's query, "of what occupation are you?"

So that takes us to the industrial revolution, a time when the use of raw materials and chemicals increased with the increase in factory processes. It is questionable how much chemical safety and hygiene training actually took place. Given the time, lack of widespread expertise in IH, lack of related laws, available jobs, and the need for workers, it's doubtful much real or effective training took place.

It should go without saying that Alice Hamilton (considered by many to be the mother of IH) and her considerable contributions to the field of IH and specifically to chemical hygiene training were invaluable, especially for her relatively unprecedented work with working women--a previously overlooked and unprotected group. During World War II and into the 1950s, chemical use dramatically increased, as did the need for well trained workers. Unfortunately, so did worker exposures for the most part. There wasn't a lot of time, effort, or thought given to effects of chemicals.

It wasn?t until OSHA was created in 1970 that chemical usage, its inherent hazards, and training for workers started to be studied in detail by the government. Interestingly and coincidentally, it was in 1970 that Malcolm Knowles, considered the father of adult learning and education, published "The Modern Practice of Adult Education" (more on this later).

OSHA started to develop the Hazard Communication Standard (HCS) in 1974. The rule finally was promulgated in 1983, and the 1987 revised rule expanded coverage to non-manufacturing industries. But the important change to the rule (from the perspective of training) occurred in 1994, when OSHA added one little word to the training requirements: "effective." That one word carries a lot of importance with it. OSHA felt it important enough to add it. Why, you ask? Good question. Simply put, because they had found most HazCom training to be ineffective--it didn't work, it didn't do anything. It often consisted of distribution of material safety data sheets (MSDSs) and/or a generic HazCom video with little opportunity for worker questions or interaction with a competent instructor. Here's what OSHA says "effective training" means (taken from its recently released "Draft Model Training Program for Hazard Communication," a must read for anyone responsible for HazCom training or in general):

Effective means that the information and training program must work. Employees must carry the knowledge from the training into their daily jobs. For example, if asked, they should know where hazardous chemicals are present in their work area, and should also know how to protect themselves.

That pretty much brings us to the present day. Let's turn more to what adult education theory and practice tell us is truly effective training (of any sort, not just HazCom).

Adult Learning and Education Theory
In his 1970 book, Malcolm Knowles defined andragogy as "an emerging technology for adult learning." He said that when it came to learning, adults:
1) move from dependency to self-directedness;
2) draw upon their reservoir of experience for learning;
3) are ready to learn when they assume new roles; and
4) want to solve problems and apply new knowledge immediately.

Accordingly, Knowles suggested adult educators should:
* set a cooperative learning climate
* create mechanisms for mutual planning
* arrange for a diagnosis of learner needs and interests
* enable the formulation of learning objectives based on the diagnosed needs and interests
* design sequential activities for achieving the objectives
* execute the design by selecting methods, materials, and resources; and
* evaluate the quality of the learning experience while re-diagnosing needs for further learning

All of this sounds great! Self-directed learners (workers) drawing on their extensive experiences, ready to learn (especially with new roles, such as new chemical usage), and wanting to solve problems and apply knowledge immediately! When is the last time you experienced this in HazCom training? Aye, there's the rub, as someone once said. Let's look at the problem and then, later, the solutions.

The Problem: Ineffective Training

Actually, it's hard to know where to start; there are so many ways in which training can go bad. But there is one leading culprit. For learning to occur, there has to be a transfer of some sort. No transfer, no learning. Usually this transfer is information (but not always), and that is the first problem: too much of an emphasis on information.

Don't get me wrong; information is a good thing. In particular, chemical hazard information is vitally important and of course is the basis for Hazard Communication. It is in the MSDSs, on the labels, and it jam packs most HazCom training. It's information overload and because of this, most HazCom trainers try to overstuff the training with tons of useful information, assuming you can cram the information into the student and later he'll "regurgitate" the information--perhaps for the OSHA Compliance Safety and Health Officer (How's that for a visual?) From an adult learning perspective, this just won't work. Why, you ask?

All you have to do is to look back in this article at Malcolm Knowles' tenets of adult learning. Adults are self-directed and not dependent. They want to draw on their experiences, and they want to solve problems and apply knowledge right away. An information-heavy approach to training does not allow for any of these in general terms. To put it quite simply, adults like a learner-centered approach, not an information-centered approach. Take a look at his suggestions for adult educators (or trainers).

In addition, perhaps it would be of benefit for us to take a quick review of some typical adult learner likes and dislikes.

Likes of Adult Learners
Asking questions
Setting learning goals
Developing agendas
Helping teach
Sharing their expertise/experiences
Fun and games
Group work

Dislikes of Adult Learners
"Needs-less" training
Being tested
Future needs
Goals set by others
Restricted topics
Being ignored
Forced learning
Preachiness or sermonizing
Talking head trainer

This brings up the question, Where do we start on the solutions to ineffective training? Great question! The first place to start on the solutions is the first place any good (and effective) training should start--with a well-conducted needs assessment.

Needs Assessments
What is this "needs assessment" I keep hearing about regarding training? A needs assessment is the process of determining what the workers' (or students') needs are. From that, we can determine to what degree these needs can be met with some form of learning or training.

Keep in mind that not all health and safety needs can be fixed with training. For instance, let's say a work group has had several chemical exposures. Training may not be the answer (or the problem). Instead, perhaps they need better chemical exposure control such as local exhaust ventilation, or different respirators, or something else entirely. But for any and all training courses, sessions, modules, or what have you, a properly conducted needs assessment is the first step.

So, where to start with HazCom training for a needs assessment? Why not start with OSHA's HCS--after all, it is a regulation. Look at the standard and see what OSHA requires for HazCom training. OSHA requires training on:
* Methods and observations used to detect hazardous chemical releases;
* Physical and health hazards of the chemicals in the work area;
* Measures employees can take to protect themselves from these hazards; and
* Details of the HazCom program (labeling and MSDSs) and how to use it.

Additionally, OSHA requires that employees be given the following information (there's that word again):
* Requirements of OSHA's HCS;
* Operations in their area where hazardous chemicals are present; and
* Location and availability of the written HazCom program, chemical inventory, and MSDSs.

Certainly there's more guidance available from OSHA. There is Appendix E to the HCS, Guidelines for Employer Compliance. There is OSHA document 2254, OSHA Training Requirements?. There is OSHA's compliance directive to field staff for inspection directions, CPL 02-02-038. Last but not least, there is OSHA's Draft Model Training Program for Hazard Communication Training. All of these are readily available at Just click on the "H" in the alphabet listing at the top, then on "Hazard Communications." The HazCom specific items are mostly under "compliance."

If so much information and guidance is available from OSHA, why not just stop there? OSHA knows needs assessments. It knows a proper needs assessment is specific to the workplace, the chemicals, the processes, the workers, etc. So there is more work to do. Besides, if you do stop there, you're left with an information-heavy, generic training needs assessment.

Look at the workplace, the chemicals, the processes, the workers, etc. What do the workers need to know and be able to do regarding chemicals in their areas? You can acquire this knowledge (by performing a needs assessment) in many ways. You can:
* Review it all yourself;
* Reflect on your years of experience in similar situations;
* Ask other OHS professionals for their input;
* Ask area or department managers or supervisors for their input;
* Ask the workers themselves what they feel they need;
* Look to other credible resources for the information; and/or
* Perform a combination of the above options or other ways.

Once we have the needs assessment done and verified as accurate, wherefore art thou, o? HazCom training? Why, on to learning objectives, naturally.

Learning Objectives: They Must be "DMO"
"DMO" stands for demonstrable, measurable, and observable. Learning objectives must be each of these. If learning is to take place, then there must be some form of transfer. The learning objectives "set" what this transfer is. In other words, after the training, what will the student be able to do? Each thing the student will be able to do is a learning objective--something we're striving toward in the training. They must be DMO.

So objectives always start with a prefacing statement, such as, "At the end of the training, the student will be able to . . . " Then there are usually several bulleted learning objectives. All should start with an action verb, such as list, state, define, explain, demonstrate, describe, compare and contrast, etc. For instance, a HazCom training learning objective might be, "At the end of the training, the student will be able to locate the correct MSDS for the chemical they are working with within 1 minute."

By the way, there are a few "bad" words for learning objectives. These are the ones that we all too often see inappropriately used. They are not DMO. The bad ones to avoid are "understand," "know," "aware of," and "appreciate." Never use these words in your learning objectives. After all, how can you observe or measure someone's awareness of anything? So now you have your learning objectives all written. Now what? The lesson plan.

Lesson Plans
"If you don't know where you're going, how will you know when you get there?" An apt quote; can you identify the speaker? It was asked of Alice by the Cheshire Cat in Lewis Carroll's "Alice in Wonderland." The lesson plan is to the trainer what a road map and trip itinerary are to the traveler.

We have to have a lesson plan to plan, plot or "map out," direct our training course, session, or module. Lesson plans are pretty much free form and include a variety of components in sufficient detail for the trainer. Typical items in a good lesson plan include: course title; duration and start time; audio/video needs; objectives; topics and sub-topics; learning aids; activities or methods; key points; and others as preferred by the trainer.

A HazCom class may have a partial lesson plan like the following (as an example):
Class: HazCom--Do You Really Know Your Chemicals?
Time: 1 hour (8-9 a.m.)
A/V: Dry erase board, overhead projector (for cartoon), TV/VCR (for video of work site)
Objectives: At the end of the class, the learners will be able to:
* Name the chemicals they work with;
* Find the MSDS for each product in 2 minutes; and
* Explain, in general, the hazards of the chemicals in the products.
Topics: Chemicals used, MSDSs, labeling system (NFPA diamond), our chemical inventory, how to read an MSDS, OSHA's HCS, questions.
Learning aids: MSDSs, chemical inventory book, videotape of worksite, cartoon, "volcano" to demonstrate pH, example chemicals from production floor, NFPA diamond, student handouts, OSHA standards (as backup for questions), little "prizes," and food.
Activities: Game--ID the chemical, Top 10 myths of OSHA's HCS, contest--help your teammate locate the right MSDS, coloring by numbers the NFPA diamond, deciphering an MSDS--a how-to guide.
Key points: OSHA's HCS and our written program are to protect you!
The MSDS has the information on the chemical hazards!
The NFPA diamond is a simple labeling system in use here!
It's easy to get the information you need (with help) if you know where to look and how to read it!
Other: Don't forget the coffee and food!

Now, with a plan in place, it's (finally) off to perform the training.

Stand and Deliver--the Training
OK, stand, sit, however you're most comfortable and makes sense for the class and setting. This is the part everyone sees, but look at how much goes into the development and preparation for the actual delivery of training: a lot, and that's my point.

You have to do the prep work properly for the training to work or be effective. So often it is skipped over, going right to someone standing in front of a group lecturing about the OSHA standard and showing an MSDS on the overhead in tiny type. Arrgh!

Most important is to teach toward the learning objectives. They came from your needs assessment and, as you'll see, they flow into the "student learning evaluation process." As you could see in the lesson plan and in the table of adult learner likes and dislikes, there are so many other possibilities for good HazCom training. Yes, you have a lesson plan to go by, but like a road map it is the planned route. Sometimes it's worth it to stray a bit off course. Maybe a travel companion (a/k/a student) wants to learn more about a specific aspect of the chemical you're discussing. Great, he wants to learn--that?s what you want, the prototypical self-directed adult learner. Feed that need. Teach him what he wants to know and he'll appreciate it and will (want to) keep coming back to your classes--also what you want.

There are all sorts of ways of making training more fun and engaging. If you haven't done so already, try asking them what they want to learn in today's class, and then deliver that. Encourage discussion among the students and facilitate it. Jump in to steer them in the right direction as needed or to "clear up" any misconception on the part of students. (The trainer do's and don'ts list would be much too long to fit into this article--there are literally hundreds of each.)

After the class, then what--a test? In the words of Monty Python, "Run away!"

To Test or Not To
Probably you can already tell I'm not only not going to tell you to always test them, but also that I'm not likely a big fan of tests. Here's my point: How many of you are good test takers? Some, but not many. How many of you actually like to take tests? What about your students? (Do you know what a test is best at testing? One?s ability to take a test.) Anyway, a test is not necessarily an end-all, be-all for evaluating students' learning. What is? The learning objectives, of course. What were those three letters or words good learning objectives had to be? DMO: demonstrable, measurable, and observable. Look back at the objectives--they are how you evaluate the students' learning. After all, you said that "at the end of the class, the students will be able to. . . " So, can they? That is the best measure of your students' success in the class. In our HazCom example, we said they'd be able to:
* Name the chemicals they work with;
* Find the MSDS for each product in 2 minutes; and
* Explain, in general, the hazards of the chemicals in the products.

So it follows that all we have to do is to evaluate them on these three learning objectives. Can they name the chemicals they work with? It doesn?t have to be a standard type of written test; instead, make it a game. Have them do it orally and evaluate one another. (You'll find they cheer and root for one another to succeed. Isn't that great?) Next, can they find the MSDS in two minutes? Obviously suited for a contest. Last, can they explain, in general, the hazards of the chemicals?

Again, do it orally and make it fun or a challenge. What about documentation? That?s easy--use a checklist that you (or the other students helping you) fill out. It should list the training class, date, student name, learning objective, and what you observed the student do, what the student did to demonstrate it, and how you measured it. (DMO again!) Then you and the student both sign and date it.

So we evaluated the student. What about evaluating the trainer? Good, we all need to be evaluated so we can improve for the next time--and in HazCom training there is always a next time.

Evaluation: Forms, Forms, Forms
We've all seen them, used them, and filled them out: those ubiquitous evaluation forms. What are they good for?

Statistical comparisons mostly, it turns out. First we must figure out just what and why we're evaluating the training. If to improve the class, how about improving it before it ends. If that?s your game (and it should be) then we're talking about "formative evaluation," which occurs midstream in the training and allows for mid-course corrections along the way. So go ahead, make their day: Evaluate the training before it's half (or all) over. How? Try asking them or asking a co-presenter. Ask yourself and answer honestly.

The end-of-class evaluation is called "summative evaluation." Its purpose is solely for the next time the class is given and regarding the trainer(s). Forms don't work real well, but they are darned easy to do. Also, they make statistical comparisons (between courses, trainers, groups of students, course reruns, etc.) a lot easier than other types of evaluations.

First of all, get rid of the numbers on the form; just ask for "comments." After all, they are really what is most useful for improvements anyway. The most helpful evaluations I ever received were when I gave the students blank pieces of paper and asked that they write anything about the course and me. I got a lot of very useful, constructive feedback (and no, it was not all bad; it was mostly good). Oral feedback can also be of help, but that points to the problem with student evaluations. First, they must be anonymous. Second, realize there is usually some sort of teacher-student bonding that occurs, thus causing reluctance on the part of most students to offer negative criticisms. Here are some alternatives:

* Peer review. Have a fellow trainer observe you and offer gentle and constructive feedback. Typically, you then return the favor.
* Audits. No, not the IRS-type audit. These often are performed by an accrediting body but can be performed by anyone knowledgeable in training, the subject matter, and who has a checklist of the training session's various components--a matrix, if you will.
* Videotape. It's the best--and the worst. Basically, you tape yourself (or have another tape you, especially if you move around a lot). Then you watch the videotape--in private, with the door locked. I wouldn't suggest selling tickets and popcorn for this showing. It can be a bit painful but is a good eye-opener as far as seeing yourself from the students' perspective. You learn a lot from watching yourself. But it is effective--as will be your next HazCom training. Which brings us back to where we started.

The End?

Well, sort of yes and sort of no. It is the end of the article, but it is by no means the end of the training--either your next HazCom class or your (or my) further learning about training fellow adults. We should strive to be lifelong learners. If you're a dedicated trainer, my guess is you already are a lifelong learner. Be the most effective trainer you can be and offer the most effective HazCom training you can, by putting the learner back into the training!

This article originally appeared in the September 2004 issue of Occupational Health & Safety.

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