A few months ago, I was meeting with a potential client when the conversation turned to employee safety training. "Oh yeah," he said, "We have a real formal safety training program. Once a month, we show the guys a safety video."
"Well, showing people a videotape isn't training," I said.
His smile faded and a blank look came over his face. "What do you mean that's not training?" he asked quizzically. It was deja vu all over again as I once more explained OSHA's published policy on using videotapes for training.
In short, showing employees a 20-minute videotape on fall protection or letting them spend a few hours with an interactive computer-based program on confined spaces is not sufficient to meet OSHA training requirements. A variety of letters of interpretation from OSHA's national office make it abundantly clear that although videotapes and interactive compact discs may be used as part of a training program, simply showing employees these materials does not meet the training requirements imposed by standards such as confined spaces, lockout/tagout or scaffolding.
Think about it. There isn't a department of motor vehicles in the country that will let someone get behind the wheel of a car and drive after watching a 20-minute videotape or completing an interactive computer-based training program. Clearly, things such as confined space entry, lockout/tagout and scaffold erection demand far more knowledge and skill than driving a car. So how can anyone believe that workers would be trained on these and other equally complex topics after watching a videotape or completing an interactive computer program?
Training vs Education
The terms "education" and "training" have very specific meanings. However, like many other pairs of terms such as "accuracy" and "precision," they often are incorrectly used interchangeably in conversation.
"Accuracy" relates to how close a measurement is to the true value, whereas "precision" has to do with how reproducible a related set of measurements are. One can be precise without being accurate. For example, if you are aiming at a bull's eye and consistently hit the top right corner of the target, your shooting is very precise, but not very accurate.
Just as there's a big difference between accuracy and precision, there's a big difference between education and training. One can be highly educated without necessarily being trained. Organizations such as the American Red Cross have known this for years, which is why you can't be certified in first aid or CPR just by taking a written exam. You have to demonstrate that you can do certain things.
Similarly, no police department in the country puts its officers on the street with loaded weapons after a lecture on marksmanship. Each officer has to qualify on the range by demonstrating that he or she actually can hit a target.
Education is a process through which learners gain new understanding, acquire new skills, or change their attitudes or behaviors. The educational process is complex and learning usually takes place on many levels. An educational program can be successful even if the learners cannot do anything new or different at the end of the program. If the program's goal was simply to inform the participants of certain facts, it would be considered a success if the participants could demonstrate that they knew those facts at the end of the session.
For example, at the end of an educational program on lockout/tagout, participants may be able to explain why lockout/tagout is necessary, define various terms related to lockout/tagout, describe types of lockout/tagout hardware, and list equipment that must be locked out. But this knowledge doesn't mean that they have the skills required to identify the types and magnitude of various energy sources and are able to properly lock out a piece of equipment.
Similarly, participants in a confined spaces seminar may be able to discuss the nature of atmospheric hazards, describe the theory of operation of various instruments and explain why calibration is necessary. This doesn't mean that they are able to properly test the atmosphere in a confined space and interpret the results of those tests.
Training is a specialized form of education that focuses on developing or improving skills. While training incorporates educational theories, principles and practices, its focus is on performance. The goal of training is for learners to be able to do something new or better than before.
Further evidence of this clear distinction between education and training can be found in the OSHA standards. Specifically, 29 CFR 1910.155(c)(14) defines education as "....the process of imparting knowledge or skill through systematic instruction," while 29 CFR 1910.155(c)(41) defines training as "...the process of making proficient through instruction...in the performance of assigned duties." [Emphasis added]
In short, the principal criteria in determining if training has been effective is whether the participants can demonstrate proficiency in carrying out the tasks in which they were trained. If participants can perform the tasks, the training has been effective. If they can't, it hasn't.
OSHA Standards Require Demonstrated Proficiency
Many of the standards OSHA has issued in the last 20 years include provisions for training. OSHA also has been making it increasingly clear that it is not sufficient merely to ensure that employees be provided with safety-related training materials; they must be able to do certain things as a result of the training they receive. A few selected examples:
Personal Protective Equipment. 29 CFR 1910.132(f)(2) requires that employees demonstrate that they know how to use personal protective equipment.
Confined Spaces. 29 CFR 1910.146(g)(1) requires that employees who work as entrants, attendants or entry supervisors have the understanding, knowledge and skills necessary for the safe performance of their assigned duties.
Respiratory Protection. 29 CFR 1910.134(k)(1) requires that each employee be able to demonstrate how to inspect, put on, remove, use, and check the seals of respirators.
Lockout/tagout. 29 CFR 1910.147 (c)(7)(i) requires that employees have the knowledge and skill required for the safe application, use and removal of energy controls.
Laboratory Safety. 29 CFR 1910.1450 (f)(4)(i)(C) requires that employees be trained in the specific procedures necessary to protect themselves from chemical hazards, including appropriate work practices, emergency procedures and personal protective equipment to be used.
Ladders and Stairways. 29 CFR 1926.1060(a) requires that employees be able to recognize hazards related to ladders and stairways.
Evaluating Training Effectiveness
Because training is skill-based, there is only one way to evaluate the effectiveness of a training program. That's to determine if participants can demonstrate proficiency of the required skills. For example, the effectiveness of a training program on instrument calibration can be evaluated by watching people demonstrate how to calibrate an instrument on which they have been trained. If they can't do it, the training was not effective.
Yes, they may have sat in a room for 20 minutes and listened to a vendor talk about the calibration process. They may have witnessed a calibration demonstration. They even may have nodded in agreement as the salesman explained that calibration was a snap. But the proof of the effectiveness of a training session rests with whether they actually can demonstrate the required skill.
How About Retraining?
A number of OSHA standards, such as hearing conservation, respiratory protection, bloodborne pathogens and lead, require annual training. Other standards such as confined spaces, fall protection and lockout/tagout, require retraining whenever there is evidence which suggests that employees who already have been trained no longer possesses the requisite understanding and skills.
As a practical matter, additional training should be provided whenever there are changes in the workplace that render previous training obsolete. These changes may include such things as:
- Changes in systems or equipment.
- Changes in procedures or methods.
- Employees are assigned new duties and tasks.
There is a big difference between education and training. Simply showing employees a safety videotape isn't training. In addition, just knowing more about a particular subject isn't enough. For training to be effective, participants must be able to do something new or better than before.
What's OSHA's Position on Videotapes and Computer-based Training?
OSHA has written a number of letters of interpretation that clearly and unambiguously outline the agency's position not only on the use of videotapes and computer-based training, but also on the need for employees to be able to demonstrate certain skills. The most relevant passages of selected letters is provided below. The full text can be found on OSHA's Web site at www.osha.gov.
In an April 15, 1992 letter to James R. Cross, an attorney for Infection Control/Emerging Concepts Inc. of Springfield, Va., Patricia K. Clark, OSHA's then director of the Directorate of Compliance Programs, stated that:
"Training the employee solely by means of a film or video without the opportunity for a discussion period would constitute a violation...."
"While training programs are certainly appropriate for use as an aid in training, they must be supplemented with the required site-specific information, and a person must be accessible for interaction."
"Compliance officers will determine, on a case-by-case basis, whether the training that has been provided is effective and adequate. This is accomplished through observation of work practices and employee interviews in an effort to determine that the training (including written material, oral presentations, films, videos, computer programs, or audiotapes) is presented in a manner that is appropriate to the employees" education, literacy level, and language."
In an Oct. 11, 1994, letter to Gerald J. Joy, health and safety director, ICF Kaiser Engineers, Inc. in Pittsburgh, Ruth McCully, then director of Health Compliance, wrote:
"In OSHA's view, self-paced, interactive computer-based training can serve as a valuable training tool in the context of an overall HAZWOPER training program. However, use of computer-based training by itself would not be sufficient to meet the intent of the standard's various training requirements. Our position on this matter is essentially the same as our policy on the use of training videos, as the two approaches have similar shortcomings."
"OSHA urges employers to be wary of relying solely on generic 'packaged' training programs in meeting their training requirements. Training required under HAZWOPER includes site-specific elements and should also to some degree be tailored to workers' assigned duties."
"Hazardous waste operations can involve many complex and hazardous tasks. It is imperative that employees be able to perform such tasks safely."
OSHA's position on this matter was reaffirmed in a letter dated June 11, 1997, that Stephen Mallinger, acting director, Office of Health Compliance Assistance, sent to Anna E. Jolly, Circle Safety and Health Consultants, LLC. In that letter, Mallinger restated that, while "Interactive computer-based training can serve as a valuable training tool in the context of an overall training program...use of computer-based training by itself would not be sufficient to meet the intent of most of OSHA's training requirements." Like McCully, Mallinger cautioned employers to be wary of relying solely on generic "packaged" programs in meeting their training requirements.
In his June 20, 1996, response to a question concerning training under the lockout/tagout standard raised by Neil Wasser of Constangy, Brooks & Smith in Atlanta, John B. Miles, Jr., then director, Directorate of Compliance Programs, wrote that "[a]uthorized employees must be initially trained and retrained so as to ensure that they have the skills and knowledge of safe application, use and removal of lockout or tagout controls called for in each energy control procedure. Each authorized employee must be able to safely perform the work required in any energy control procedure which he or she is called upon to use, however rarely."
Contributing Editor John Rekus, PE, CIH, CSP, is an independent safety consultant and author of the National Safety Council's Complete Confined Spaces Handbook. With more than 20 years of OSHA regulatory experience, he specializes in conducting OSHA compliance surveys and providing safety seminars for workers and managers. He resides near Baltimore and may be reached at (410) 583-7954 or via his Web site at www.jfrekus.com.