Boiled down to its essence, your legal obligation with respect to safety training is fourfold:

• Provide training to your workers;
• Keep records so you can prove you furnished training;
• Take steps to ensure that your training is effective; and
• Keep records documenting your verification efforts.

We've talked about the first two. Let's finish the series by discussing the last two. There are also two forms in the Tools section of SafetyXChange - a model quiz and verification form - that you can use to document your efforts to verify the effectiveness of the training you provide.

4 Things You Can Do to Make Sure Your Workers "Get It"

To satisfy OSHA/OHS training requirements you must make an active effort to verify that workers retained the lessons you taught them. The effort must be ongoing. That means you need to test, reinforce and make adjustments. In the words of one expert: "Any safety coordinator looking for a bright blinking light to go off on the worker's helmet to let them know the lesson has been absorbed is going to be quickly disappointed. You must come to grips with having to continually engage the worker to gauge his ability to apply learning to the workplace."

There's no magic formula. There are, however, at least four techniques that safety professionals recommend using to evaluate and enhance the effectiveness of your training:

1. Post-Training Quiz. Have workers take a quiz after the training session to test their understanding. Workers who don't score a certain percentage should get additional training. Repeat the quiz a few weeks or months later to ensure that workers retain what they were taught. The Model Quiz in Tools (Tool 1) is based on a Hazard Communication course taught by North Carolina State University.

2. Participant Demonstrations. After you explain the right way to perform a job, get the worker to show you how to perform it. For example, watch whether forklift operators are stacking pallets the right way and driving safely. "Simply asking the worker whether he understands what you told him isn't enough," says a safety consultant from Syracuse, NY. "A lot of times, workers will tell you that they understood what you said even if they didn't, either because they don't want to seem dumb or because they want to get training over with."  But with a demonstration workers can't hide what they did and didn't absorb. Actual performance of the technique is also a pedagogical device. "Demonstrating the technique shows the worker how to perform it better than anything else," notes the Syracuse expert.

3. Post-Training Evaluation. You should have some form of evaluation to get worker feedback on the training. There are lots of different techniques - interviews, questionnaires, focus groups and even informal chats. One expert says she requires workers to fill out a Comprehension & Understanding form.

4. Post-Training Observation. The only sure way to determine if training is effective is to observe what the workers do when they get back to the jobsite, according to one consultant. For example, if you're training on lockout/tagout (LOTO) and three days later you observe workers locking out their machines before cleaning, it's a sign that they remembered something from the training program you just held. If you see them doing the same thing three months later, it's a sign that your training was effective, notes New Jersey safety consultant Barry Weissman.

Keep Form Documenting Verification Methods

As we saw earlier in the series, some OSHA standards, such as the one for process safety management, require employers to keep documentation of the methods they used to verify that workers understood their training program. To meet this requirement, prepare a form for each worker that lists the methods that you used to make sure your safety message sunk in. Be sure that your form describes:

• The training subject for which worker understanding was verified;
• The method of verification;
• The date that the verification took place; and
• Whether additional training is necessary and if so, the date on which such training was provided.

Keep the form in each employee's personnel or training file and update it every time you provide additional training or re-test a worker.

Conclusion

If you've read this whole series, you should understand why simply handing workers a safety manual and having them sign an acknowledgement "proving" that they received and read the material isn't enough to keep you in compliance with your legal obligations under OSHA and OHS laws. For training to make the grade, it must be dynamic, interactive, continual and constantly updated and reaffirmed.

TOPF INITIATIVES SPONSORS SAFETY HERO

SafetyXChange welcomes Michael Topf and Topf Initiatives as sponsor of the 2007 Saxcie Award for Safety Hero of the Year. Topf Initiatives is one of the most successful and admired consulting firms in our industry. It's not simply the firm's 25 years of experience in helping companies in a variety of industries take their environmental, health and safety programs to the highest levels; what makes Topf Initiatives special is that it has pioneered the Holistic Integrated Approach to EHS training which is light years ahead of most other behavioral-based safety programs.

The other thing that distinguishes Topf Initiatives is that it's the creation of Michael Topf, our good friend and one of the founding fathers of SafetyXChange. To find out more about Topf Initiatives and how it can take your company to the next level, see www.topfinitiatives.com, or call (610) 783-1776.

SAXCIES™ NOTES

Finalists Chosen: SafetyXChange is pleased to announce that finalists for the Saxcies™ Awards have been chosen. Click here to see them.

Thank you to everyone who submitted a nomination. If your nominee didn't make it to the finals, don't feel too bad. Once again, we were overwhelmed by the quantity and quality of the entries, making it very difficult to select only five finalists for each category.

Winners will be announced at the SafetyXChange members' reception during the American Society for Safety Engineers Conference in Orlando, Florida on Tuesday, June 26.

The Saxcies™ Reception: We invite you to join us in Orlando on June 26 for the presentation of the Saxcies™ awards. If you want to attend, click here to receive your invitation. Please be sure to RSVP as soon as possible, because space is limited.

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