New To Your EHS Role? Don’t Let Training Fall Through the Cracks
Safety training software can help ensure your training program is effective.
- By Mary Schulz
- Jun 01, 2022
Whether you’ve joined a new company or have been promoted from within, taking on an EHS management role can be daunting. You’re responsible for assessing processes and determining where to update existing safety protocols or implement new ones. You’ll be called on to collaborate across teams to identify and fix on-site hazards before they can lead to serious incidents. You’re also charged with overseeing compliance with myriad safety standards and for reporting the performance of EHS programs to company leadership.
With so many responsibilities in your new role, inevitably—and normally unintentionally—some tasks will be overshadowed by others. Unfortunately, one of the most often overlooked obligations is training. Ensuring workplace EHS training meets applicable regulations, standards and best practices is a fundamental responsibility for EHS professionals and is also one of the most challenging. Year after year, on OSHA’s list of top ten violations, training failures are among the most-cited provisions of cited standards.
Let’s look at why safety training is so important and ways software can help ensure your training program is effective, compliant and top of mind.
Training and Why It Matters
Training is so critical because it is the most direct way to engage workers with your EHS programs and in your workplace EHS culture. It’s how your employees learn to do their jobs safely, effectively and in accordance with regulatory rules, guidelines and standards. It’s how you make sure that your EHS programs and policies are reflected in the day-to-day work your employees perform. It’s also one of the best ways to gather feedback from your people about what issues they are encountering, what constraints they feel and where gaps exist between intentions and reality.
OSHA and other regulatory agencies also require training. While the General Duty Clause of the 1970 Occupational Safety and Health Act simply states that employers must provide, “Employment and a place of employment which are free from recognized hazards that are causing or are likely to cause death or serious physical harm,” training plays an important role in helping employers to meet their obligations. Additionally, many OSHA standards lay out explicit requirements for training and measurements of training efficacy, as summarized in OSHA’s guidance document Training Requirements in OSHA Standards. Similarly, you may find that specialized training is required for certain groups of employees depending on their job functions and applicable regulations. For instance, a forklift driver must be trained in the proper operation and maintenance of a forklift, according to OSHA’s Powered Industrial Trucks Standard.
The timing of EHS training also matters. People need to know how to do their jobs safely before they start working on a new task or in a new area of the facility. People also need to know what to do if an incident or accident happens. Some regulations establish specific timing requirements for training. For instance, the Hazard Communication (HazCom) Standard requires employers to train all workers about chemical hazards and key elements of the employer’s HazCom program such the method of providing access to safety data sheets (SDSs) and must provide this training at the time of their initial job assignment, and whenever a new chemical hazard the employees have not previously been trained about is introduced into their work area. Employers who fail to provide proper training when they need to provide it not only are out of compliance with HazCom requirements but also create risks for their employees and their business.
Beyond training on specific tasks, employers should also pay attention to the environmental conditions where the work takes place. Are employees exposed to potential hazards that require additional monitoring or precautions, such as gauges or meters? Your training should reflect that. Keep in mind, too, that training requirements may vary based on location, with certain states having their own, often more stringent training requirements in specific regulatory areas.
How Online Training Software Can Help
Even when employers understand the importance of training, they often struggle to do it right, make it a priority or properly resource it. Additional headwinds come in the form of shifting regulations, changing processes and policies, new facilities and equipment, and an evolving workforce. In short, training needs are constantly changing, and as the EHS professional in charge, you must stay agile and keep finding time to address these challenges head on.
Let’s look at the two areas where safety professionals often have training challenges—training cadence and training temporary workers—and ways training software can help.
Training has a way of becoming fossilized, with many companies falling into an “annual training” mindset with their training programs. Once a year they dust off their training materials and go through the motions of walking the workforce again through the same things they covered the year before. This “annual training” mindset makes it easy to neglect needed training updates, puts employees at risk and takes your company out of compliance with important training requirements. OSHA rarely specifies training frequency requirements outside of certain, specific regulations; instead, OSHA requires training whenever it is necessary for the health and wellbeing of workers. Actions that can trigger training responsibilities include the introduction of new chemical hazards into the workplace, the introduction of new machines, changes in processes and workplace conditions.
You may also need to retrain if you find evidence that the training was not as effective as anticipated. It’s not enough to provide training, or even document training, although of course you should. But you should pay special attention to ensuring and verifying that training is effective, which means employees can demonstrate their understanding and put the training into practice. When that is no longer the case, you must retrain them, even if the original training didn’t occur long ago.
A centralized cloud EHS software solution is an effective tool for helping to ensure you’re not just meeting critical training requirements but also maximizing employee performance against your training program. The best solutions combine interactive EHS training content, powerful training management tools and advanced tracking and reporting features that keep learners more engaged and connected with your training program.
These programs remove the guess work around training needed by helping you identify upcoming or past-due training requirements and send automated in-app user notifications directly to the specific employees who need training. With a more accurate visualization of your training program performance, you can more quickly generate training records and reports to demonstrate your workforce is up-to-date on all training needs. It’s also easier to test the efficacy and retention of your training on an employee-by-employee basis and do “spot training” to shore up deficiencies as they occur.
Another area where a comprehensive learning management system (LMS) with dynamic training courses is useful is meeting temporary worker training requirements. For instance, many employers assume the staffing agency handles HazCom training for temporary workers, but OSHA’s guidance in its Temporary Worker Initiative (TWI) makes it clear that the Agency expects the staffing agency and the host employer to share responsibility for effectively informing and training temp workers regarding their exposure to hazardous chemicals. Each employer has a regulatory obligation to train their workers on chemical hazards they may experience in the course of their work, even if other employers are the source of those hazards.
OSHA recommends that the staffing agency and host employer discuss responsibility for each aspect of HazCom training and inform the other when it is completed. Keep in mind that this must be done before the worker begins work on a project and before a new chemical hazard is introduced that the worker has not previously been trained in. Additionally, the training must be in a language and vocabulary the worker understands. Depending on the industry, worksite and job duties involved, other OSHA standards that also require site-specific training may be applicable.
Comprehensive LMS software helps eliminate the confusion around temporary worker safety training needs by automatically identifying and assigning required courses, and recording training completion to reference, if needed, later on. And because all training occurs online, temporary workers are able to complete all necessary courses in their own time—on their own devices—before they enter the workspace.
Keeping Training Top of Mind
Now that we’ve covered some basics of safety training and how software helps to overcome common training challenges, it’s important to think about how to build a sustainable training program.
If you’re new to an EHS role, you’ll find that making training a priority early-on will substantially increase your overall safety program success. Substandard training isn’t just a waste of time and energy; it’s a massive risk to your people and business. If you haven’t done the work to ensure that employees are well-informed and trained to do their jobs safely, you could be exposing them to deadly risks and putting your business at risk of debilitating fines, and possibly irreparable damage to your reputation.
Effective training is more than just a safety imperative; it’s how top-performing organizations maximize worker morale, productivity and retention. And with the growing focus of environmental, social and governance (ESG), building an effective training program isn’t just about safety and compliance, it’s key to running a successful business with an engaged workforce.
Advances in safety training software give employers greater control of what employees are being trained in, and how courses are administered—all for a lower cost and greater ROI than many traditional, classroom-style training programs. As importantly, it helps meet the realities and expectations of the modern workforce.
Adopting a purpose-built training software solution to coordinate and track your training activities, deliver interactive e-Learning content in the language your employees understand and easily document training compliance ensures training remains a priority across your organization. Your workers get an immersive and engaging learning experience while you gain versatile administrative controls and reporting features that simplify even your most complex training tasks and help you stay focused on larger EHS risks and best practices.
This article originally appeared in the June 2022 issue of Occupational Health & Safety.