By George Chelovich and Michael Ladd
Increasing customer demands and requirements place an enormous stress on a precaster’s ability to deliver high-quality products with shorter lead times. As a result, when combined with leaner supervisory and production staffs, the ability to develop and schedule environmental health and safety training has become much more difficult.
Yet the need for properly trained employees in the area of occupational health and safety is more important than ever, especially new employees. That’s because OSHA has finalized its new Hazard Communication Standard (HCS), aligning it with the Global Harmonization System (GHS) for classifying and labeling chemicals(1).
The new system substantially changes the existing HCS. Employers must train all employees on the new rules by Dec. 1, 2013. Additionally, employers must learn new chemical classification criteria, replace all Material Safety Data Sheets (MSDSs) with new Safety Data Sheets (SDSs), and update or replace chemical labels by the phase-in dates noted on OSHA’s website. OSHA has developed a specific website to provide highlights and details that employers should be aware of and training requirements(2).
Four steps to a safer workplace
With the new HCS training requirements in mind, let’s take a look at a simple example of how a four-step process can be applied to the requirement for retraining.
Step 1 – Assessment. The first step is an analysis of the value that training brings to the business. There are many reasons to train workers: proper orientation; understanding of company standards, policies and procedures; regulatory compliance; prevention of accidents; and so forth. A quick assessment should be done to ensure that all are properly identified and prioritized.
The assessment process in this scenario is straightforward. Implementing HCS training provides value to the organization in two ways: It satisfies the regulatory requirement for training and thus reduces the probability and financial impact of an OSHA violation; and more importantly, it provides workers the opportunity to better understand the hazards of the materials used in the precast manufacturing process.
Step 2 – Development of training objectives. Training metrics should be created to evaluate the effectiveness of the training provided. Rather than focusing on the number of people trained or the total hours of training, define the impact you want to achieve as a result of the training. One of the key elements in occupational safety and health training is to teach employees the behaviors that will maximize production and minimize accidents.
In this example, the training objective is to ensure employees have the information they need to better protect themselves from chemical hazards in the workplace as new labeling requirements and SDSs are being reformatted.
Training may be limited to a few people or given to the entire workforce. Some employees may be required to wear personal protective equipment (PPE), others may have PPE available to them and use it on a voluntary basis. In either case, the training should include a refresher on the application and use of PPE.
Step 3 – Determination of required employee behaviors. The need to identify necessary employee behaviors and actions required at the job class level within your facility that will achieve the level of accidents, productivity and quality acceptable to your organization is critical. Once specific behaviors are identified, you can determine the right training methods that fit your organizational style.
The following is not a complete list of expected behaviors, but it illustrates the types of behaviors desired. Employers need to evaluate their production processes and create employee behaviors based on the machinery and equipment used, their production processes and skill levels of their workforces.
- Employees wearing the proper protective equipment and clothing
- Employees inspecting their PPE prior to use
- Employees using the proper tools in chipping, grinding and cleaning activities
- Employees using approved containers for chemicals/materials
- Employees reading SDSs on new chemicals and materials
- Employees promptly reporting problems, concerns and health effects
Step 4 – Testing and workplace application. Step four is to establish clear objectives for training that can be measured through testing and workplace application.
Requiring employees to determine the proper PPE needed in a specific scenario, inspect it and wear it can be one criterion for passing the training.
There should be a post test and follow-up audit to ensure the effectiveness of the training. The post test should cover the main concepts of the training, specific requirements of the regulation, testing on the new label requirements and SDS formats, as well as the behaviors that will be expected after the training.
The follow-up audit would consist of an observation of employee work practices against the desired behaviors as well as short interviews with employees ensuring their retention on labels and SDSs. An employer may also measure the effectiveness by the number of employees observed wearing their PPE correctly.
If a high number of violations are observed in employee behaviors, knowledge of labels and SDSs, or PPE usage, then retraining should be considered.
The retraining requirement for the revised HCS can be summarized quickly in the following table:
The new OSHA standards have placed high importance on HCS training, which, as mentioned earlier, must be completed by Dec. 1, 2013. This four-step process is a simple example, but it provides one possible framework for your own training syllabus.
Ask your insurance carrier whether it can provide at least some of the safety training. This training may come in the form of classroom training, online training, ePresentations, webinars or any combination of these methods to fit your operation and training objectives. No matter how you add it up, an effective safety program = a safer working environment = fewer incidents = minimal insurance costs.
George Chelovich, CNA Insurance Co., has been in the insurance industry for 36 years, 26 of which have been with CNA. He started as a field consultant, has held various field and staff management positions, and is currently the assistant vice president of Risk Control’s construction, manufacturing and technology segments. His technical areas of expertise are workers’ compensation, ergonomics and machine safeguarding.
Michael Ladd is the consulting director of industrial hygiene services for CNA Insurance’s Risk Control department. He is a certified safety professional, a certified industrial hygienist and an Underwriters Laboratory-recognized risk engineer. He has more than 30 years of experience providing various consulting health-hazard services to a wide range of manufacturing, construction and service industry clients.
Sidebar – How Effective is Your Safety Training?
A recent claim analysis by CNA Insurance of its manufacturing customers indicates that more than 40% of employee injuries occur to those with less than two years experience. In these competitive times, it is much more difficult for employers to spend three days in a classroom teaching the theories of occupational safety and health as they relate to their operations. Training in today’s environment requires that employers use the most effective methods that can be accomplished in relatively short time periods.
A 2010 National Institute for Occupational Safety and Health (NIOSH) study on the effectiveness of training and education for the protection of workers found that the most engaging methods of safety training are, on average, approximately three times more effective than the least engaging methods in promoting knowledge and skill acquisition. They also found that the most engaging methods of safety training are, on average, most effective in reducing negative outcomes such as accidents. They defined “engaging methods of training” as training activities that included behavioral modeling, simulation and hands-on training.
“Moderately engaging methods of training” consisted of programmed instruction techniques, including computer-based instruction and feedback techniques. The “least engaging methods of training” involved such activities as lectures, films and video-based training.
Their results suggested, however, that moderately and highly engaging training methods are, on average, more time consuming and probably more expensive in the short term but that they are potentially less costly and more effective in the long term while better ensuring worker and public safety.
(1) The Hazard Communication Standard Final Rule is available for download as an 858-page pdf file at https://www.osha.gov/dsg/hazcom/GHSfinal-rule.pdf. Also see “GHS: A New World Order for Safety” in the January-February 2013 issue of Precast Inc.