Regardless of any language barriers, OSHA requires safety training.
By Gustavo A. Gonzales
In a previous article we touched on the importance of safety orientation training for new employees and the benefits derived from that training. OSHA 29 CFR 1910, General Industry Standards, as well as most of the various Canadian Occupational Safety and Health regulations, also require the employer to provide continuous or specialized training to the employees under other standards.
While some regulations explain in detail the required training, others do not, or they may refer to other sources such as ANSI (American National Standards Institute) or NFPA (National Fire Protection Association). These non-government associations also publish standards that are incorporated by reference into the OSHA Standards, which means that any training specified by them is also required by OSHA.
What is required?
In general, OSHA requires that all employees be trained in the materials and equipment they work with, the hazards present and how to control them.
It is also expected that no employee will perform any job or operate any equipment until he or she has been properly trained and is authorized to perform the job. No employee should perform any job that appears unsafe.
For the precast industry, a list of some of the required training must include:
• Personal protective equipment
• Hazard communication or “The Right to Know”
• Lock-out or the isolation of energy
• Respiratory protection
• Blood-borne pathogens
• Forklifts or any power industrial truck
• Confined spaces
• Overhead crane operation
• Hearing protection
• Employee emergency plan
• Fire prevention plan
• Safe operation of machinery, equipment and power tools
• Welding and cutting operations
• Fall protection
This is by no means a complete list, and your operation may require training in a variety of other topics that are not covered here. It is also important to remember that regulations may change from time to time, and we may have to adjust the training accordingly.
The training process
Training is the process of communicating information to employees who may or may not have any knowledge on the subject in which they are going to be trained, and then verifying that they have understood what we taught them. It is a two-way interaction between the trainer and the trainee in order to explain a process, an operation or a safety-related subject.
There are two types of training: formal and informal. In informal training, the supervisor or trainer discusses specific safety topics with employees either through one-on-one conversations on the plant floor or in a group setting. Formal training is usually conducted in a class or office, and it may involve computers, presentations or videos conducted by a trainer who can explain the subject and answer questions. Sometimes it will also include practical evaluations, such as in forklift and overhead crane safety training.
Regardless of the method used, training must be understood by the employee in order for it to be effective. As a general rule, adults retain 10 percent of what they read, 20 percent of what they hear, 30 percent of what they see, 50 percent of what they see and hear, 70 percent of what they say or repeat, and 90 percent of what they say and do. As you can see, there is a remarkable difference between providing material to read and setting up a demonstration.
Language barriers provide a special challenge to safety trainers in the precast industry. Based on my own experiences as a trainer and manager for Hispanic work forces, I have observed the following characteristics of some Spanish-speaking employees in precast plants:
• Most, if not all, have never received safety and health training.
• Some have trouble reading – either Spanish or English.
• Bilingual supervisors, who themselves lack proper safety training, are sometimes placed into positions where they must explain hazards to workers.
• The need to provide for the family outweighs the danger of being placed in harm’s way of an accident or injury.
• When they have safety concerns, most are afraid to talk about them.
• They are more frequently employed in trades that pose safety and health risks.
However, all immigrants are not the same just because English is not their native language. Culturally, they may have different attitudes, values, beliefs, behaviors and even vocabulary. It’s a reality that makes safety training and communication even more difficult.
How to conduct training
OSHA requires safety training regardless of language barriers, and the employer must provide that training and assert that such training has been understood. It is important to emphasize that most, if not all, of this training requires that the company have in place programs or policies that adhere to the OSHA standards and Canadian regulations. In the case of OSHA they must be site specific. This is a case where one size does not fit all, so if you purchase or obtain a “generic” program it will have to be customized to your operation.
The best approach to safety training is to have managers, supervisors or safety coordinators who are fluent in both languages and can offer the necessary training in Spanish and even translate the needed material. This is the ideal situation, because communication is established and information flows. Plus it helps to eliminate the “culture” barrier.
The second approach used by some plants is to present the material in English and have a lead person or supervisor translate the training to the employees. The problem with this method is that a lot is missed during the translation and the employee does not really get the full benefit of the training. In some cases, office employees with no experience in safety training are placed in a position to deliver the content, which may result in ineffective training.
A third approach is to purchase training programs written in Spanish and give them to the employees to read. Without the benefit of a qualified trainer, this can be disastrous, because the employee may not understand the dialect in which it was written or, worse, may not be able to read Spanish at all! If you must use this method, however, purchase videos or CDs that allow the trainees to both hear and see the content at the same time.
OSHA, the CDC (Center for Disease Control, www.cdc.gov) and NIOSH (National Institute of Safety and Health, www.cdc.gov/niosh) have quite an array of Spanish materials available on their Web sites. You can also obtain the same material in English and Spanish through the eLCOSH (Electronic Library of Construction Occupational Safety, www.cdc.gov/elcosh) of the CDC. Another good source is the Oregon OSHA Web site: Visit http://egov.oregon.gov/DCBS and search for the PESO program. Also, the National Precast Concrete Association (NPCA) offers several Spanish-language resources from its online bookstore “The NPCA Shop” at www.precast.org.
If your plant is located in an area of heavy Hispanic influence, you will be able to find bilingual safety professionals who can develop your policies and programs as well as your training materials in both languages. They will also be able to present this training in Spanish and English to your employees.
If you use verbal or visual presentations, try to include as many pictures or objects as possible to help communicate your ideas. If you are teaching electrical safety, for example, provide an extension cord with a ground and one without so that they can see the difference.
Do not take yes for an answer
One practice among trainers is to ask the trainees whether they understood the material presented to them. The answer is generally a “yes” or a nod of the head, which usually means that they have no idea what you just said.
Remember, most employees, Hispanics or not, are afraid to lose their jobs or do not want to appear ignorant in front of others, so their responses will be “yes.” Try using other methods to see the effectiveness of your training such as asking questions or asking them to explain to you what they just heard.
One effective method is to administer a short written test on each subject at the end of the presentation. This is not a “pass or fail” test, but a way to determine their level of knowledge on the subject and for their understanding and comprehension. If they do not know an answer, review the material with them and explain it in detail until you are sure they understand it.
Listen to what your safety trainees have to say, and you will be surprised at the results. Once you have gained their confidence, they will be more forthcoming about problems or hazards that they are aware of but are afraid to volunteer on a regular basis.
Remember, training is required by law, and it is the employer’s responsibility to offer that training in a manner that it is understood by the employees. Training for training’s sake serves no purpose and does not make an employee safer. On the other hand, when no training is offered at all because communication is almost nonexistent, the risk for accidents increases.
Gustavo Gonzalez has nearly 20 years of experience in the precast concrete industry and safety. He has a bachelor’s degree in Industrial Engineering Technology from Florida International University and is a former precast concrete plant manager. He is an instructor and Spanish translator for the National Precast Concrete Association and an OSHA Outreach Trainer.