Moving Beyond Reactive Safety

Employers should review the hazards associated with each job task in order to determine the level of safety training provided.

• By Dave Terry
• Sep 01, 2014

Transportation of goods, materials, and equipment is integral to operations in every industry, and many organizations rely on the safety of transportation personnel to maintain their operations. In order to maintain operations and ensure personnel safety, exceptional training is required.

Each location is unique in the hazards and challenges operators face, which is why adequate training is the keystone to transportation safety and operational continuity. Employers often are unfamiliar with the requirements of a training program and lack the experience to implement an effective training program.

Employers are required to train, test, certify, develop training, and retain records accordingly. Many employers choose to have outside consultation perform training, testing, and certification, which is often performed away from the work location and covers general concepts. Conventional safety consultants offer training on general subjects such as transportation safety, which creates a dependency on consultation to maintain compliance. Consultation is recommended to help develop specific training and implementation programs or assess program health and recommend corrective actions. This methodology moves away from traditional safety consultation and enables employers to effectively manage their programs and review the structure of their training program.

Specifically targeted at transportation, each operator must receive general awareness, or familiarization, training for the location, which may include, but not be limited to these: surface conditions, pedestrian traffic, ramps, closed environments, and any unique or hazardous environmental conditions. Because hazards and situations change between job tasks or even shifts, individual training or review of the specifics should be reviewed prior to releasing an operator to perform work.

The Value of Equipment-Specific Training
Equipment-specific training must be designed to provide the operator with the knowledge, skills and abilities to correctly operate the equipment assigned. Employers often establish generic training to provide all operators with general skills to potentially perform an array of jobs.

A common mistake is providing training in a "rodeo" setting, or warehouse, and certifying operators based on basic equipment functions. This is a management system error and prepares the operator for failure, which is often blamed on the operator for their inattention to detail or hurrying through tasks.

Arguably, equipment-specific training is the most important element during training because it establishes a base knowledge for the operator of how to perform job-specific tasks. If training is rushed, misses steps, fails to familiarize personnel, or does not prepare operators adequately, then the business is susceptible to errors and potentially injuries; both of which result in direct costs.

A few examples of equipment-specific training include, but are not limited to, these: operating instructions; warnings; differences between equipment, controls and instrumentation; motor operation; visibility, inspection and maintenance; refueling and operating limitations. Depending on the specific vehicle and application, additional topics must be covered to adequately prepare operators.

Specific safety training must be provided for operators based on the hazards in the workplace and the personal protection measures to reduce exposure. This training will be extremely variable depending on the business and job task, which may include environmental conditions (heat/cold) or extensive hazardous material training. Employers should review the hazards associated with each job task in order to determine the level of safety training provided.

Some locations, operations or hazmat personnel may require security awareness training that includes security risks associated with their specific tasks and methods designed to enhance security.

This application of training is not conclusive for all industries, and each employer must assess its workplace(s) and determine with which regulations and requirements it must comply. Requirements are not established to qualify as training, but each employer must determine the adequacy of training according to its needs. Workplace training requirements can be modeled after Federal Motor Carrier Safety Regulations (49 CFR - Transportation), but references should be made to OSHA (29 CFR - Labor) and EPA (40 CFR) requirements for specific industries, hazards, and training or protection requirements.

Keep an Eye on State, County, and Local Requirements
Some employers fall into the misconception that federal regulation compliance is absolute. Many states, counties, and local authorities have more strict requirements or have specific requirements regarding standards, policies, and procedures. Lower levels of authority are often overlooked in fear of non-compliance with federal requirements. Regardless of industry or application, each employer should seek advice from consultation familiar with standards in their region to determine additional compliance requirements. Some laws may directly affect, or be influenced by, demographic strengths.

In Kern County, Calif., it is illegal to transport hay without a bill of lading or proof of purchase. Additionally, in Youngstown, Ohio, it is illegal to run out of gas. Although these laws are examples of extremes, they are no less real, and they require employers to abide by them.

Companies employing highway transportation that involves personnel with potential to pass vehicles on a two-lane highway should be aware there are only two states that allow vehicles to exceed the speed limit while passing (Montana and Washington state).

When determining how to develop and implement a training program, an employer's priority must be to ensure safety training complies with local, state, and federal requirements. After program development or evaluation has completed, employers need to determine how well the program provides business operations with safe and efficient operators. Implementation verification begins with auditing and assessment protocols, which many companies call Validation & Verification (V&V). Implementation verification goes beyond transportation safety training and is another subject, but setting higher standards provides companies with leading indicators and moves away from reactive safety. After all, safety is first aid for the uninjured, and the most important asset of every company is the people performing the work.

This article originally appeared in the September 2014 issue of Occupational Health & Safety.