The problem with OSHA-mandated training isn't documentation, it's quality. Most standards that require training don=E2=80™t directly require documentation; Powered
Industrial Trucks is an exception, but even there what gets documented is the certification that the training leads to. Nevertheless, employers almost always "document" the training so they can prove they did it. That's usually done by a sign-in sheet. But
that only documents attendance. OSHA will cite if the required training wasn't done, but I've never seen a citation for poor training.. In the agency's defense, it would be hard to sustain, given how subjective the judgement would be.
Many of our employers do very good training, and they'd do it even if OSHA didn't exist. A lot of it is designed by joint safety committees, and delivered by
experienced workers - both in classroom and on-the-job. We=E2=80™ve also designed modules on hazard communication, process safety management, accident investigation and what we call "systems of safety," which is an expansion of the hierarchy of controls.
Sadly, however, some employers skimp on training. We've seen cases where a 10-minute video gets teed up, during which everybody signs a sheet, and bingo-they're
all trained. We once ran a little contest to find the shortest employer hazard communication training. The winner came in at a little over three minutes.
We're also seeing a lot of OJT training being done by inexperienced workers, either because there's high turnover or because management doesn't want to assign
the more experienced and productive older workers. We call it "green training green," and it's a real problem.
The Hazwoper standard at least requires minimum training hours, but it's an exception. MSHA is a lot better. New miners get a week of classroom training (except
in surface stone, sand and gravel operations), and then an 8-hour refresher every year. That doesn't guarantee quality, but it helps.
One last point: we use the word "training" a lot, but we really prefer "education." They may be synonyms, but to us, training deals with how to do a job. Education
is a more thorough grounding in why it's done that way and how that job fits into the more general process. We've had fatalities where people followed the job steps precisely, but circumstances had changed in a way they didn't fully understand.
Mike
Michael J. Wright
Director of Health, Safety and Environment
United Steelworkers
412-562-2580 office
412-370-0105 cell
"My friends, love is better than anger. Hope is better than fear. Optimism is better than despair. So let us be loving, hopeful and optimistic. And we'll change
the world."
Jack
Layton
From: ACS Division of Chemical Health and Safety [mailto:DCHAS-L**At_Symbol_Here**Princeton.EDU]
On Behalf Of Monona Rossol
Sent: Friday, October 23, 2020 8:09 PM
To: DCHAS-L**At_Symbol_Here**Princeton.EDU
Subject: EXTERNAL EMAIL: Re: [DCHAS-L] Fwd: OSHA COVID-19 Tip of the Day for October 23, 2020
There are many laws like Hazcom that require documented training. I have a list somewhere of about 15 such laws. Monona
-----Original Message-----
From: Daniel Kuespert <0000057d3b6cd9b7-dmarc-request**At_Symbol_Here**LISTS.PRINCETON.EDU>
To: DCHAS-L**At_Symbol_Here**Princeton.EDU
Sent: Fri, Oct 23, 2020 4:12 pm
Subject: Re: [DCHAS-L] Fwd: OSHA COVID-19 Tip of the Day for October 23, 2020
No, they cannot. As I recall, there was a court decision (OSHA v. Westvaco?) that held that OSHA cannot require any documentation not specifically asked for by
a reg. The decision had to do with the Process Safety Management standard, which has specific documentation requirements, and OSHA tried to cite Westvaco for not having some docs that they weren't required by reg to have. Annoyingly, I cannot find the reference,
though. Might have been OSHRC, rather than a court, but I can't find it there either.
Figure on it this way: if it hasn't been through public review and comment (via the Administrative Procedures Act processes), then they'd be free to require different
docs of different companies, which is kind of the definition of "arbitrary and capricious."
Regards, Dan
On Oct 23, 2020, at 15:17, DCHAS Membership Chair <membership**At_Symbol_Here**dchas.org> wrote:
I found today's Covid tip from OSHA odd. It's a "good idea" to document safety training? OSHA doesn't require this documentation?
- Ralph
Subject: OSHA COVID-19 Tip of the Day for October 23, 2020
Date:
October 23, 2020 at 9:11:04 AM GMT-4
This email was sent to
ralph**At_Symbol_Here**rstuartcih.org using GovDelivery Communications Cloud on behalf of: United States Department of Labor =B7
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Ralph Stuart, CIH, CCHO
Membership Chair
American Chemical Society Division of Chemical Health and Safety
