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Health and safety plan shouldn't end with training
Editor's note: This article is the fifth in a series that provides a primer for ANSI Z10, the voluntary consensus standard for health and safety management systems approved in 2005. The first four articles are available online at www.ncacc.org/rmp.htm. In April's CountyLines, we briefly discussed implementing and operating an occupational health and safety management system (OHSMS). Part I of the discussion covered the basic operational elements, including the hierarchy of controls, management of change, procurement, contracting and emergency preparedness. This month, we continue the discussion with a review of training, communications and program documentation. Education, training, awareness and competence This is the most critical piece of the organization's OHSMS. Many incidents occur in the workplace because a person either was not trained or did not retain what they learned in a training course, or the need for training in a particular topic was never identified to begin with. Initially, the organization must assess what training needs to be provided. It is pretty easy to see which jobs need special licensing or certification – these are more easily justified and identifiable. The difficult part is determining the other training needs – for example, does everyone need to know about all the chemicals that are used throughout the entire county government? By answering these questions up front, it is then easier to move on to organizing the training effort and needs. Safety training should address the following categories of employees: New employees: Orientation on safety hazards that they may encounter. This includes mentoring and follow-up to ensure the new employee understands the hazards faced in a new job, in a new environment. Veteran employees: Include refresher training and training that addresses particular issues or when new hazards are discovered. Safety committee members: Includes hazard identification, investigation techniques and spotting unsafe behaviors. Supervisors: Hazard identification, investigation techniques and spotting unsafe behaviors (Nope, not a typo – many things we ask our safety committees to do are more effective if also done by supervisors!). Special employee groups: This includes mobile workers, law enforcement staff, paramedics, building inspectors and others whose jobs may be "out of the norm" in comparison with your administrative staffs. In training the employee, special consideration must be made to the method used. Adult learners need to see a need in what they are learning, as well as participate in the learning process, as evidenced by studies performed by the National Training Laboratory Institute. According to Edgar Dale's "Cone of Learning," adults retain 5 percent of what they see and hear, lending truth to the adage "telling ain't training." Dale's "Cone" shows that adults retain 75 percent of what they learn through hands-on practice, while teaching the subject or immediately applying in a real situation what has been learned results in 90 percent retention. Getting creative will pay big dividends in the long-term retention of knowledge needed to work safely. Communication Another important element of implementing an OHSMS is how communication takes place. The communication process must be formally established and intentional in three main areas in order to maintain credibility and remove barriers to effective communication that exists: 1. Progress toward the implementation of the OHSMS, with all affected levels of the organization. What has been completed? What remains to be implemented? What is the effect on employees? This information should be updated as often as necessary, as it builds buy-in and commitment with both employees as well as managers. 2. Prompt reporting of all work-related incidents, including injuries, illnesses and close-call incidents. The latter is extremely important. There have been many occurrences of where post-incident investigations have uncovered conditions or circumstances that have been in existent for months or years earlier, but were not reported or corrected. Had close calls received attention, a catastrophic incident may have been prevented. 3. Having a formal system to report, track and correct hazards in the workplace is closely related to incident reporting. Employees know better than their manager, the safety committee, or even the risk manager of what safety hazards exist in the work area. The employee should be encouraged to report these hazards and also to make recommendations on how to correct them. Document and record control The final step in implementing a formal OHSMS is determining what should be documented and what records should be maintained. Retaining proper records can allow the effectiveness and performance of the management system to be tracked. The records provide a demonstration and assessment of the conformance with applicable standards. Policies, procedures and OSHA-required programs such as for HAZCOM, Confined Space Entry and Respirator Protection, should be dated, and all revisions documented. Incident records, to include insurance claim files, OSHA injury logs, hazard tracking and collection forms and training logs, should be maintained as necessary. Some of these have particular retention periods specified in codes and standards. These records should be stored in the same manner as other important documents and records. Our series continues next month with a discussion on how to measure and audit the effectiveness of the OHSMS once it has been established. As Risk Control Manager for the NCACC, Bob Carruth, a current Cabarrus County commissioner, manages the operation of the Risk Control Team for the Risk Management Pools. The team assists members with development of safety policies and programs and identification of liability exposures and controls. |