HRH Safety and Health Systems

What is required?

In general, OSHA requires that every employee be trained in the materials and equipment they work with, the hazards present, and how to control them.
It is also expected that no employee will perform any job or operate any equipment until he or she has been properly trained and is authorized to perform such job. In addition, that no employee should perform any job which appears unsafe.

The training process

Training is the process of communicating information to employees who may or may not have any knowledge on the subject in which they are going to be trained and verification that they understood what we taught them. Training is a two-way interaction between the trainer and the student in order to explain a process, an operation or a safety subject.

There are two types of training, formal and informal. During informal training, the supervisor or trainer discuss with the employee(s) ways of doing things. This can be accomplished by having a one-on-one conversation with an employee on the plant floor or by addressing a group of employees in a toolbox meeting. Formal training is usually conducted in a class by a trainer who is able to explain the subject and answer questions from the audience. Sometimes, formal training must also include practical evaluations.

Regardless of the method used, training must be understood by the employee in order to be effective. As general rule, adults retain 10% of what they read, 20% of what they hear, 30 % of what they see, 50 % of what they see and hear, 70 % of what they say or repeat, and 90% of what they say as they do. As you can see, there is a remarkable difference between giving them a paper to read or setting up a hands-on demonstration.

The new challenge

The Bureau of Labor Statistics, which is part of the Department of Labor, reports that in “2006, 937 Hispanic workers were fatally injured while at work. Hispanic worker fatalities accounted for 16 percent of the 5,703 total fatal work injuries that occurred in the U.S. in 2006. The rate of 4.7 fatalities per 100,000 workers recorded for Hispanic workers was a 21 percent higher rate than the rate of 3.9 fatalities per 100,000 employed recorded for all workers. In 2006, foreign-born Hispanic workers accounted for 632 fatalities or 67 percent of the fatalities to Hispanic workers.” The Hispanic worker can be an “immigrant” or native born in the U.S. Hispanic workers are one of the largest non-English speaking minorities in the United States. According to figures from the Census Bureau, Spanish speakers grew by about 60 percent and Spanish continued to be the non-English language most frequently spoken at home in the United States in 2000. Hispanics continue to be the largest minority group at 42.7 million. With a 3.3 percent increase in population from July 1, 2004, to July 1, 2005, they are the fastest-growing group. By 2050 the U.S. Census Bureau projects that there will be about 102 million Hispanics in the U.S. or about 24 % of the population.

The U.S. Census Bureau, 2006 American Community Survey estimates that on the present population of Hispanics 5 years or older 52.7% speaks English very well and 47.3% speaks English less than well.

These reports indicate that the Hispanic workforce is growing strong in this country and that employers need to recognize the importance of adapting their training programs and methods to create a safety culture among the Hispanic employees in order to reduce the amount of accidents and fatalities which may be attributed to a lack of proper training, poor training methods or language barriers.

The new worker

The majority of immigrant workers are good, hard workers, but from the safety point of view, the Hispanic immigrant worker represents a completely new challenge to the industry. Based on my own experiences during the years that I have spent training and managing Hispanics the following characteristics have been observed:

1. Most, or none,  have never received safety & health training
2. Some can barely read either Spanish or English.
3. Bilingual supervisors, who themselves lack proper safety training, explain hazards to workers
4. The need to provide for their family outweighs the danger of placing themselves in harm’s way of  an accident or injury.
5. When there are safety concerns, most are afraid to talk to OSHA
6. Language and cultural barriers
7. More frequent employment in the more dangerous trades

Another trend exhibited by some Hispanic immigrants is a riskier approach to work based in the “macho, or machismo” concept which is part of the culture and it is demonstrated by taking higher risks and not accepting help.

Another common mistake is to lump all “Hispanics” together as if they are all the same.  Depending on the country from which they came, Hispanics may have different attitudes, values, beliefs, behaviors and even vocabulary.

How to conduct training

The best approach to training is to have managers, supervisors or safety coordinators which are fluent in both languages and can offer the necessary training in Spanish and even translate the needed material. This is the ideal situation because communication is established and information flows. Besides it helps to eliminate the “culture” barrier. The second approach used by some companies is to have the material in English and have a lead person or supervisor translate the training to the employees. The problem with this method is that most of the time a lot is missed during the translation and the employee does not really get the full benefit of the training.

In some cases, office employees with no knowledge of safety deliver the content and they are not able to explain much of the material.

A third approach is to purchase training programs in Spanish and give them to the employees to read. This can really create problems because we do not know if the employee understands the Spanish in which it has been written, or worse yet, we do not know if the employee can read Spanish at all!  I have seen a lot of translations in which I have questioned the content or meaning of the material even though I fully understand the subject at hand.

If your plant is located in an area of heavy Hispanic concentration, then you will be able to find bi-lingual safety professionals who can develop your policies and programs, as well as, your training materials in both languages. They will also be able to present this training in Spanish and English to your employees.

If you use verbal or visual presentations, try to include as many pictures or objects as possible, this will help to communicate your ideas.  For example, if you are teaching electrical safety have one extension cord with a ground prong and one without a ground prong.  Using those as visual aids, you can explain why a ground prong is necessary and the employees can see the difference.

Do not take yes for an answer!

One practice among trainers is to ask the audience if they understood the material presented to them. And the answer is generally a “yes” or a nod of the head, which usually means that they have no idea of what you just talked about.

Remember, most employees whether they are Hispanic or not, are afraid to lose their jobs or do not want to appear ignorant in front of others.  Their natural response will be a “yes”. Instead, try using other methods to evaluate the effectiveness of your training.   For example, asking questions or asking employees to explain back to you what they just heard.

One effective way is to give them a short written test on each subject at the end of the presentation. This is not a “pass” of “fail” test, but a means to look at their level of knowledge, understanding, and comprehension of the subject.  If they did not know an answer, then go over it with them and explain it in detail.  Then you will know that they understand the material.

Be a good listener and hear what they have to say.  You will be surprised at the results. Once you have gained their confidence they will start telling you all kinds of problems or hazards of which they are aware off but are afraid to volunteer the information.

Remember, training is required by law and it is up to the employer to offer that training in a way that it is understood by the employees. Training for training sake serves no purpose and does not make an employee safer. On the other hand, when no training is offered because communication is almost non-existent and management and labor are barely able to communicate, then the risk for accidents increase and the disregard for human life become apparent.

The Occupational Safety and Health Administration (OSHA) Sept. 30 released a proposed rule that will modify the existing Hazard Communication Standard.  The updated standard will conform to the Globally Harmonized System of Classification and Labeling of Chemicals used by the United Nations.   

Specifically, the proposed rule includes revised criteria for chemical hazard classification; revised and standardized labeling criteria that will include pictograms; and a specific format for safety data sheets.  The revisions also contain requirements that will force every employer that currently has a hazard communication plan to train its employees on the new standard within two years of implementation of the final rule.  OSHA estimates this portion of the proposed rule will affect more than five million businesses for a total annual cost to employers of $100 million.  

In addition, OSHA is proposing to modify provisions of other standards, including standards for flammable and combustible liquids, process safety management and most substance-specific health standards to ensure consistency with the modified Hazard Communication Standard.   

Because of the broad scope of the proposed rule and the training requirements it contains, ABC is assessing the impact of the proposed rule on the construction industry and will likely submit comments before the Dec. 29 deadline.

The Occupational Safety and Health Administration Oct. 1 announced revisions to the two enforcement policies under the Steel Erection Standard.  

Under the revised policies, steel studs that bind concrete to the steel, known as shear connectors, must be installed at the worksite.  Previously, employers were allowed to weld the shear connectors on the ground before attaching them to the building.  

The other updated policy requires that employers install a floor or net beneath workers within two stories or 30 feet, which ever is less.

The Occupational Safety and Health Administration (OSHA) is launching a pilot program to monitor recordkeeping on construction and mobile worksites.   

The pilot program is being launched in conjunction with a national emphasis program (NEP) that is currently focusing on non-mobile worksites.  OSHA will begin monitoring construction and other mobile job sites once the pilot program is complete.   

The current NEP on recordkeeping directs OSHA inspectors to analyze all injury and illness records between 2007 and 2008 for the jobsite being monitored.  Inspectors will then reconstruct the OSHA 300 forms from that information and compare them to the forms that were actually filed.  The program was launched Sept. 30 and will expire in one year.   

ABC will monitor the progression of the pilot program for the construction industry and keep members updated.  

For more information, click here.  

In my last blog, I pointed out that any organization could implement a safety culture providing that management made the necessary commitment.

For construction companies, safety comes down to minimizing injuries on construction sites.  If injuries can be minimized, then the next step is figure  out how injuries can be eliminated.  Therefore, we have the “zero injury” concept where the goal is eliminating all injuries.

At first glance, the natural reaction is that no one can predict what will or will not happen on construction sites.   People are unpredictable, therefore no one can foresee an event that might result in personal injury.

However, once the type of work activities that result in personal injury are identified, then ”predicting” potential injuries becomes a process of elimination.  We begin the process with Job Hazard Analysis.

Any work activity can be broken down into its component parts.  Therefore, each work activity contains elements that contribute to potential injury during the performance of that task.  The idea here is once the hazardous elements are identified, then training or re-training employees to avoid those elements can be accomplished.

I worked with an industrial engineer years ago and he taught me basic time and motion study.  Using this knowledge enabled me to analyze work activities and determine both the most efficient and safe way to perform a task.  A Job Hazard Analysis is nothing more than a very simplified version of a time and motion study.

Most construction workers are not properly trained to do their jobs safely and efficiently.  I see an enormous amount of wasted time and effort on construction sites.  This lack of training has a direct correlation to poor job performance and results in unnecessary injuries.

Construction companies could dramatically improve the quality of their projects and virtually eliminate injuries by taking a hard look at employee training and determine what kind of training is needed.  Safely performing a task should be a part of any job training offered to employees.

Lee Phillips, Safety Consultant is the first contributor to our blog.