Can You Hear the Training Now?
There is no correct, best, or worst training effort. The main things to remember are consistency and repetition. Any information has to be repeated in order for us to actually remember and put it to use.
Shift the focus of your workplace hearing conservation program for a moment and evaluate exactly what you are trying to accomplish. You have an excellent written program that includes monitoring, annual training and the best PPE on the market. However, with a hidden hazard of hearing damage, "one and done" attitudes toward compliance will only give you a false sense of security. Your program will only succeed if the employees understand the true need and use all PPE correctly and consistently.
While the requirement is to provide training annually . . . the reality is training and awareness are needed more often to reinforce, remind, and repeat to ensure your program is effective.
Know What You Need
Do your safety professional homework for the company up front. Sound surveys, inspections of equipment, sampling where needed, and effective engineering controls in place. How many employees will be affected?
Then, develop a plan of action to help you as the program moves forward. All a plan of action does is list the various steps you need to accomplish, breaking down the big picture into smaller "doable" tasks.
Training Format and Frequency—Does It Really Matter?
Print handouts, posters, dynamic displays, tailgate meetings, samples demonstrations, mentoring, one-on-one, online, on-site, language, tone and frequency. Does it matter? (Let me put this simply: Yes!)
Thankfully, long gone are the days of an employer placing a container of ear plugs in the breakroom for everyone to use and thinking this fulfilled his program’s needs. Employers are taking the need for a comprehensive program to heart (and pocketbook), with excellent results. OSHA's www.osha.gov has a step-by-step guide for program elements, which is a great starting place, and other websites, including those of PPE vendors, have excellent tools for your use in many formats.
The web is full of sample programs, training elements, visuals such as video/DVD, vendors, consultants, training specialists, and products to keep the message fresh and changing in order to promote interest. Depending on your need and budget, you can find the simplest to the most complex training you can imagine, whether you are trying to do everything alone or have a team to assist.
There is no correct, best, or worst training effort. The main things to remember are consistency and repetition. Any information has to be repeated in order for us to actually remember and put it to use. Annual training is required—regular, routine training and refreshers are what is needed to make the program shine because your employees fully understand and apply the information. Repeat, repeat, repeat, but in such a way that the employees actually absorb the message.
Ask and Observe—Often and At All Levels
I remember well the days of being an OSHA compliance officer and by the time opening conference was completed for one inspection, the shop floors were littered with hearing protection wrappers. No one was fooled and, more importantly, no one was helped by this action. Such antics instantly make the employer look inept and shady to the inspector and his/her employees. You want to take pride in your program efforts, not be the brunt of employee jokes. They know when you are taking foolish shortcuts.
As a safety professional assessing the hearing conservation efforts to really find out whether/how your employees are using hearing protection, start in purchasing. Track back several years and determine the volume of PPE purchases and replacements by department and by even shift/supervisor, if possible. Note when your hearing conservation program began and the last real training the company provided and what format was used. Jotting down the data on a quick spreadsheet is very helpful with this if the size of the company is mid-range or small. Then correlate any hearing-related injuries by department. Add in the testing and how often it is done, by whom, and how quickly for new employees it is completed. Do they sign anything indicating compliance guidelines? How many languages are represented? Do you provide an interpreter when needed? Are there any other disabilities to note? Review the safety committee minutes and also annual reports if possible for additional clues.
Observe your employees at work. Are they comfortable with the PPE, or is it obviously a newly introduced item for them to wear as show? One great idea is to have a couple of different options for PPE with you and ask whether a couple of employees would like to try the sample items. Discuss the program strengths (and weaknesses) while they exchange out the PPE. You will at times be amazed at how little the employee knows about why they must wear the hearing protection and other fundamentals of the program.
Are the employees actually wearing the PPE correctly? I always ask one really important (and a little offbeat) question: "When you start your vehicle coming to work, are you ever surprised at the LOUD VOLUME of the radio?" Short of having exuberant teens driving the vehicle, this could indicate other noise-related issues for you to follow up on, such as temporary threshold shifts and why employees’ PPE is not working correctly.
Document, Document, Document
Have a file with your plan of action and keep a watchful eye on it as you move forward. Keep a sample (and date it) for every training, refresher, and demonstration item that is provided to the employees so you can know and prove what was done. Consider what works the best and rotate the methods. All training does not require a classroom setting, just the employee’s attention and interest. Use the format that adapts best for your employees. If you used printed media and poster items, do rotate them regularly so that employees will notice the new message.
Hearing loss is a life-altering workplace injury that often goes unnoticed compared to lacerations, for example. We assume the best, but without monitoring the program the damage is done before the costs are calculated. It takes effort but, with some innovative thinking out of the box and even assistance from safety committee members, you can have an effective, appropriate hearing conservation program that improves overall workplace safety.
Safety is a true compassionate service, and we as safety professionals have the knowledge, skill, and stick-to-it-ness to be successful long term and at the same time keep the program elements interesting. If your employees understand truly what is at risk and the stakes involved for their personal lives, they will comply much better.
2016 Hearing Protection Training Program Checklist
While no checklist is a substitute for a safety program, it serves as a "reminder" of areas to focus additional attention as you strengthen your safety leadership role. Consider the following on your own or in discussions with employees or your safety committee:
1. You have an effective safety program on site that includes a comprehensive hearing protection program?
2. An assessment for possible areas requiring hearing protection hazards has been conducted at your facility. This in-depth assessment includes needed surveys and equipment assessments for possible engineering controls?
3. In conjunction with management, you have developed a plan of implementation for hearing conservation program elements, including structural items such as engineering controls, equipment changes, audiometric testing, area surveys for noise levels, training costs, and PPE items needed for all affected employees?
4. Each position has been evaluated for duties that require hearing protection? Does this include temporary workers? Do you have a full list of all positions at your facility? Is it updated as needed or when processes change?
5. Your on-site workers' comp representative (or whoever maintains the OSHA logs) knows how to record hearing-related injuries correctly and the protocol for reporting this back to Safety so that corrections can be initiated?
6. There is a record of all training that has been completed on your site for hearing conservation and all employees who attended this training? Were follow-up surveys done to show effectiveness and how much information was retained?
7. Updates to training and awareness for supervisors are provided regularly and new training/awareness items are shared with them on a regular basis. Do supervisors know what to look for with hearing protection non-compliance—behaviors such as wearing only one ear plug or only partially having muffs on? Is this documented? Is it maintained?
8. Employees and supervisors are fully trained on hazard potential, safe work practices for each job requiring PPE, and required PPE that must be worn while working? Is this done prior to start of the job or through on-the-job training? Are employees allowed to ask questions?
9. Employees understand the danger of not wearing required PPE? Do they understand the potential for hearing damage that can occur? Do you have any type of disciplinary system for non-compliance/repeat offenders who do not wear required PPE? Is this documented? As Safety, are you advised of these situations?
10. Do you ensure employees understand the use of PPE when needed? (And how is this done: Verbally? Skills training? Classroom? Mentor? Posters? Online? On site?)
11. Do you maintain a positive safety leadership attitude and follow the rules on the job? Are you sure? (What would your employees say about your attitude?) Do you wear PPE when needed?
12. Do all levels of management wear hearing PPE when needed? (This includes upper management, safety, visitors, etc. Have all participated in the same training as site employees?)
13. As part of their training, each employee is shown how to use, wear, clean if needed, and when to replace each item?
14. If more than one language is present in the workplace, training is conducted in the employee’s first language or translation is available to ensure understanding. What about the print items?
15. Are awareness items also bilingual if needed for employees and are they updated?
16. Are employees allowed the opportunity to ask questions concerning wearing, cleaning, and replacement of PPE for hearing protection/conservation?
17. Are hearing damage injury statistics and costs tracked for increase/decrease on a regular basis? Is this information shared with employees for feedback? Safety committee? Annual reports?
18. Purchasing statistics on type, cost, and replacement are tracked to monitor use and replacement so departments can track which products are working the best?
This article originally appeared in the October 2016 issue of Occupational Health & Safety.