Putting Chemical Safety Training to the Test
How to evaluate and improve program effectiveness.
- By Phil N. Molé
- Oct 01, 2019
As one of the main pillars of OSHA’s Hazard Communication (HazCom) Standard, employee training is a critical part of not just workplace safety, but your company’s regulatory compliance. However, HazCom training is also one of the most commonly overlooked elements of safety programs, with many employers struggling to make it effective, engaging, and relevant.
For HazCom training to be effective, those undergoing training must be able to comprehend the hazards and understand how to protect themselves. While OSHA does not expect workers to be able to recall and recite all data provided about each hazardous chemical in the workplace, the most important aspects of HazCom training are that employees are aware that they are exposed to hazardous chemicals, know how to read and use labels and material safety data sheets, and, as a consequence of learning this information, are following the appropriate protective measures established by the employer.
Outside of these parameters, OSHA gives a significant amount of bandwidth to employers to determine how they deliver training and ensure that it’s effective. That’s why ongoing evaluation is such a critical component of an effective HazCom training program. OSHA perceives training as a “performance” standard, so its value is judged by whether its objectives are achieved—basically, it makes sure employees actually know what they need to know. Without regular program assessment, it’s impossible to know the success of your training or if it needs updating.
Following training, we offer practical tips for improving the efficacy of your HazCom training program to ensure it remains engaging and useful for all employees.
Identify Information Gaps
Surveys and quizzes are an indispensable tool. Aside from scoring workers on what they’ve retained from courses taken, they’re useful for evaluating your company’s overall HazCom training program and help with identifying areas that need to be refreshed.
A good approach is to provide the same quiz to workers before and after training, and then comparing the final scores. If most employees incorrectly answer a question on the quiz both before and after their HazCom training, it may indicate that course materials need to be revised to better convey the information related to that question more clearly.
This practice is also helps to recognize any gaps you may have in your overall HazCom program. For instance, if you ask employees where the SDS binder is located and they all provide difference responses, it might not be an issue with training, but instead that the SDS binder is not located where it’s supposed to be. Without this additional evaluation, you might otherwise be unaware of the issue and unable to amend it before an incident occurs or an OSHA inspector visits.
Take Training Out of the Classroom
In the era of varied worker knowledge, retention rates, and talent gaps, the need for more dynamic HazCom training has never been greater. Traditional course lesson methods involving text-heavy presentations and stand-up lecturing are no longer effective for reaching today’s more diverse and technologically-advanced workforce. For HazCom training to be most effective, it must be interactive, participative, and directly related to a worker’s job function.
Employees respond better to HazCom training material when they understand the reasoning behind it. While visual aids help clarify, consider taking it a step further by moving certain course components to the facility floor. This method not only demonstrates the real-life implications of what is being taught but also engages workers more than a classroom setting. It’s also a great opportunity to test your people on the course elements on-the-fly in the actual settings where they would need to know the information quickly. This gives workers the chance to showcase how the lesson applies to their actual work tasks and reinforces why it’s so important to retain the information.
Remove Course Format Barriers
Today’s workforce is more diverse than ever. According to the Bureau of Labor Statistics (BLS), there were 28.2 million foreign-born persons in the U.S. labor force in 2018, comprising 17.4 percent of total workers. At the same time, age diversity is increasing at both ends of the spectrum; while it’s estimated that nearly half of all U.S. workers will be millennials by 2020, other data suggests that workers aged 45 to 59-years-old are projected to increase from 25.6 percent to 31.8 percent by 2030.
Language is another consideration. OSHA requires workers be trained in a language and manner that they understand. This means employers must account for non-English-speaking employees and any limitations in literacy level, vocabulary, or communications within your workforce. The more workers you have, the less likely it is that a “one size fits all” approach to training will work.
Another good example of that concerns the method of providing training. Look for ways to deliver the training in a way that fits the learning styles of tech-savvy millennials and more traditionally-defined Gen Xers and baby boomers. This is an area where training software helps bridge worker diversity and age gaps. A good on-demand training solution offers an extensive library of flexible online courses with content that is interactive and engaging. Shorter, more digestible training courses are particularly appealing to millennial workers, while multi-language options help ensure all employees understand the information being conveyed. Plus, freed from a centralized classroom environment, workers are able to access courses from remote locations and learn at their own pace, which helps those who are technically inept complete lessons within a timeframe they’re comfortable with.
Ditch the Annual Training Mindset
A common misconception about HazCom training is that federal OSHA requires employers to conduct annual refresher training. The reality is that the agency expects employees to be trained before they begin working with hazardous chemicals, whenever a new hazard is introduced into the workplace, and if there’s evidence that previous training wasn’t effective.
Some state OSHA plans do require annual refresher training, so you should be aware of your state requirements. Even so, remember to avoid seeing HazCom training as just an annual task, since that can be harmful to your HazCom program by causing your program to “fossilize” even as important elements of HazCom management might be changing. For instance, a rigid annual training mindset can increase the likelihood of not re-training your workers after introducing a new hazard class of chemicals into the workplace. This jeopardizes employee safety as well as your HazCom compliance.
Additionally, dusting-off the same training materials and delivering them the same way year after year is the easiest way to generate disdain among trainees. Your workers will come to loathe HazCom training, which isn’t exactly a recipe for success.
This is another area where a good training solution helps streamline organization-wide course management, so you know exactly who needs what training when. The best systems not only give you access to engaging HazCom training content but also give you the tools to schedule trainings, document and verify training completion, and have built-in email notification features that remind employees and managers when training deadlines and certification dates are upcoming or past due. Central systems for accessing and storing training tracking metrics keep your information up-to-date and make it accessible from multiple locations. These tracking tools are particularly useful for safety managers who oversee a large workforce or are coordinating training over multiple locations to ensure all local training requirements are being met.
Ensure All Workers Are Getting Trained
OSHA has stated that it expects the staffing agency and the host employer to share the responsibility for worker safety. This means that if your facility uses contract or temporary workers, you are responsible as the host employer for training them on your workplace hazards and HazCom management practices.
It is also important to keep open lines of communication with the staffing agency so you both understand the other’s roles and responsibilities when it comes to training. While the agency should be training its people on general HazCom requirements and the hazards of chemicals they regularly work with from one job site to another, you are responsible for providing site-specific hazard communication to employees. Among other things, it’s critical that the training includes how to access SDSs because this can become important very quickly during an emergency.
Keep an Eye on the Bigger Picture
While evaluating, deploying, and tracking training may seem like an overwhelming task, it’s a critical part of your company’s success. Effective HazCom training does more than just empower workers to be safe and reduce the risk of workplace safety failures or governmental fines and citations; the right tools and approach can transform a business, leading to greater productivity and contributions to the bottom line. Regular evaluation and review of your training program goes a long way toward eliminating the negative feelings employees often associate with the training process and ensures it continues to engage them with the information they need to do their jobs safely and in compliance.
This article originally appeared in the October 2019 issue of Occupational Health & Safety.