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employee training

Setting up an Employee Training Program
Voluntary Training Guidelines


Training is an integral part of your hazard communication program. Under the Hazard Communication Standard, each employer is required to inform and train employees at the time of their initial assignment to a work area where hazardous chemicals are present and whenever a new hazard is introduced into the work area.

While the outline of topics to be presented in employee information and training programs is the same for all employers, the actual information presented must be based on the specific hazard information conveyed by labels and SDSs for that particular workplace or work area.

These topics are to be covered in all information and training programs:

  • The provisions of the Hazard Communication Standard. Any operations in the employees' work areas where hazardous chemicals are present.

  • The location and availability of the company's written hazard communication program, including the required list(s) of hazardous chemicals and SDSs required by the Hazard Communication Standard.

  • Methods and observations that may be used to detect the presence or release of a hazardous chemical in the work area.

  • The physical and health hazards of the chemicals in the work area.

  • The measures employees can take to protect themselves from these hazards, including information on work practices, emergency
    procedures and personal protective equipment required by the employer.

  • The details of the employer's written hazard communication program, including an explanation of the labeling system used by the employer, SDSs, and how employees can obtain and use the appropriate hazard information on the labels and in the SDSs.

Setting up an Employee Training Program

The following sections illustrate how a typical training program might be designed. Following these guidelines is a non-mandatory training guide developed by OSHA for conducting an effective training program. Using these guidelines, together with establishment-specific label and SDS information, employers can develop effective employee training programs that achieve the objective of the Hazard Communication Standard.

Know the Provisions of the Hazard Communication Standard

  • Be familiar with the requirements of the standard.

  • Know your responsibilities under the law.

  • Inform all employees of the law and their rights under the law.

Identify those Employees to be Trained

  • Assess actual and potential employee exposure to hazardous chemicals.

  • Determine training needs based on this exposure during both normal use of hazardous chemicals and during emergencies.

  • Determine appropriate way in which to train new employees and supervisors.

  • Train employees and supervisors on the specific chemicals in your workplace and their hazards.

Know the Hazardous Chemicals in Your Workplace

Define hazardous chemicals: Any chemical that is a physical or health hazard.

  • "Physical Hazard" Physical hazard means a chemical that is classified as posing one of the following hazardous effects: explosive; flammable (gases, aerosols, liquids, or solids); oxidizer (liquid, solid or gas); self-reactive; pyrophoric (liquid or solid); self-heating; organic peroxide; corrosive to metal; gas under pressure; or in contact with water emits flammable gas.

  • "Health Hazard"Health hazard means a chemical which is classified as posing one of the following hazardous effects: acute toxicity (any route of exposure); skin corrosion or irritation; serious eye damage or eye irritation; respiratory or skin sensitization; germ cell mutagenicity; carcinogenicity; reproductive toxicity; specific target organ toxicity (single or repeated exposure); or aspiration hazard.

Make a List of the Hazardous Chemicals in Your Workplace

  • Your list should include the names of the chemicals, their hazards, and protective measures to be taken, and emergency and first-aid procedures.

  • Identify the process or operation where the chemicals are used, and the name and address of the manufacturer.

  • Make sure there is a safety data sheet (SDS) for each chemical and that the list references the corresponding SDS for each chemical.

  • Make the list readily available to your employees (or to other employers at your worksite at their request).

  • Make sure employees understand the information regarding the chemicals listed in the workplace.

Instruct Employees on How to Use and Interpret SDSs.

  • Make sure you have an SDS for each hazardous chemical product you package, handle, or transfer.

  • Check each SDS you receive to ensure that it contains all the information required by the standard.

  • Obtain SDSs or information where necessary (i.e., when SDS is not received from manufacturer, importer, or supplier, or when SDS is incomplete.

Instruct Employees on Labeling Requirements

  • Check each container entering the workplace for appropriate labeling (i.e., identity of chemicals, hazard warnings; name and address of manufacturer/importer/responsible party).

  • Explain the importance of reading labels and of following directions for the safe handling of chemicals.

  • Label, tag, or mark containers into which hazardous chemicals are transferred with the chemical identity and hazard warnings.

  • Hazard warning must convey specific physical and health hazards of the chemicals. Explain that words such as "caution", "danger", "harmful if absorbed by skin", etc. are precautionary statements and do not identify specific hazards.

  • Explain the labeling exemptions for portable and stationary process containers.

  • Label portable containers when they are not for "immediate use." (Note: Portable containers require no labels when chemicals are transferred into them from labeled containers and when the chemicals will be used immediately by the employee transferring the chemicals).

  • In lieu of labels, process sheets, batch tickets, standard operating procedures, or other written materials may be used on stationary process equipment if they contain the same information as a label and are readily available to employees in the work area or station.

  • Cross-reference chemical identifiers on labels to SDSs and the lists of hazardous chemicals.

  • Be aware of other hazardous chemicals that may have specific labeling requirements under other standards (e.g., asbestos, lead, etc.).

Review Existing Methods of Controlling Workplace Exposures

  • Engineering Controls: changes in machinery, work operations, or plant layout that reduce or eliminate the hazard (e.g., ventilation controls, process enclosures/hoods, isolation, etc.).

  • Administrative Controls: good housekeeping procedures, safe work practices, personal and medical monitoring, shortened shifts or changed work schedules, etc.

  • Personal Protective Equipment: safety glasses, goggles, face shields, earplugs, respirators, gloves, hoods, boots, and full body suits.

Review Your Current Procedures for Handling Chemicals and Compare with Recommended Practices Identified on SDSs and Labels

Consider Keeping a Record of Employee/Supervisor Training
  • Follow-up and evaluate your training program to make sure employees know how to handle the chemicals they are using and are applying the training you have given them.
Establish a Written Emergency Action Plan
  • Training in procedures such as emergency controls and phone numbers, evaluation plans, alarm systems, reporting and shut-down procedures, first-aid, personal protection, etc.

  • How and when to report leaks and spills

Training Checklist (PDF)

Employee Training Record (PDF)

Voluntary Training Guidelines

  1. Introduction

    The Occupational Safety and Health Act of 1970 does not address specifically the responsibility of employers to provide health and safety information and instruction to employees, although Section 5(a)(2) does require that each employer "... shall comply with occupational safety and health standards promulgated under this Act." However, more than 100 of the Act's current standards do contain training requirements.

    Therefore, the Occupational Safety and Health Administration has developed voluntary training guidelines to assist employers in providing the safety and health information and instruction needed for their employees to work at minimal risk to themselves, to fellow employees, and to the public.

    The guidelines are designed to help employers to (1) determine whether a worksite problem can be solved by training; (2) determine what training, if any, is needed; (3) identify goals and objectives for the training; (4) design learning activities; (5) conduct training; (6) determine the effectiveness of the training; and (7) revise the training program based on feedback from employees, supervisors, and others.

    The development of the guidelines is part of an agency-wide objective to encourage cooperative voluntary safety and health activities among OSHA, the business community, and workers. These voluntary programs include training and education, consultation, voluntary protection programs, and abatement assistance.

    1. Training Model

      The guidelines provide employers with a model for designing, conducting, evaluating, and revising training programs. The training model can be used to develop programs for a variety of occupational safety and health hazards identified at the workplace. Additionally, it can assist employers in their efforts to meet the training requirements in current or future occupational safety and health standards.

      A training program designed in accordance with these guidelines can be used to supplement and enhance the employer's other education and training activities. The guidelines afford employers significant flexibility in the selection and content and training program design. OSHA encourages a personalized approach to the informational and instructional programs at individual worksites, thereby enabling employers to provide the training that is most needed and applicable to local working conditions.

      Assistance with training programs or the identification of resources for training is available through such organizations as OSHA full-service Area Offices, State agencies which have their own OSHA-approved occupational safety and health programs for employers, local safety councils, the OSHA Office of Training and Education, and OSHA-funded New Directions grantees.

    2. Review Commission Implications

      OSHA does not intend to make the guidelines mandatory. And they should not be used by employers as a total or complete guide in training and education matters which can result in enforcement proceedings before the Occupational Safety and Health Review Commission. However, employee training programs are always an issue in Review Commission cases which involve alleged violations of training requirements contained in OSHA standards.

      The adequacy of employee training may also become an issue in contested cases where the affirmative defense of unpreventable employee misconduct is raised. Under case law well-established in the Commission and the courts, an employer may successfully defend against an otherwise valid citation by demonstrating that all feasible steps were taken to avoid the occurrence of the hazard, and that actions of the employee involved in the violation were a departure from a uniformly and effectively enforced work rule of which the employee had either actual or constructive knowledge.

      In either type of case, the adequacy of the training given to employees in connection with a specific hazard is a factual matter which can be decided only by considering all the facts and circumstances surrounding the alleged violation. The general guidelines presented here are not intended, and cannot be used, as evidence of the appropriate level of training in litigation involving either the training requirements of OSHA standards or affirmative defenses based upon employer training programs.

  2. Training Guidelines

    OSHA's training guidelines follow a model that consists of:

    1. Determining if Training is Needed

    2. Identifying Training Needs

    3. Identifying Goals and Objectives

    4. Developing Learning Activities

    5. Conducting the Training

    6. Evaluating Program Effectiveness

    7. Improving the Program

    The model is designed to be one that even the owner of a business with very few employees can use without having to hire a professional trainer or purchase expensive training materials. Using this model, employers or supervisors can develop and administer safety and health training programs that address problems specific to their own business, fulfill the learning needs of their own employees, and strengthen the overall safety and health program of the workplace.

    1. Determining if Training is Needed

      The first step in the training process is a basic one: to determine whether a problem can be solved by training. Whenever employees are not performing their jobs properly, it is often assumed that training will bring them up to standard. However, it is possible that other actions (such as hazard abatement or the implementation of engineering controls) would enable employees to perform their jobs properly.

      Ideally, safety and health training should be provided before problems or accidents occur. This training would cover both general safety and health rules and work procedures, and would be repeated if an accident or near-miss incident occurred.

      Problems that can be addressed effectively by training include those that arise from lack of knowledge of a work process, unfamiliarity with equipment, or incorrect execution of a task. Training is less effective (but still can be used) for problems arising from an employee's lack of motivation or lack of attention to the job. Whatever its purpose, training is most effective when designed in relation to the goals of the employer's total safety and health program.

    2. Identifying Training Needs

      If the problem is one that can be solved, in whole or in part, by training, then the next step is to determine what training is needed. For this, it is necessary to identify what the employee is expected to do and in what ways, if any, the employee's performance is deficient. This information can be obtained by conducting a job analysis which pinpoints what an employee needs to know in order to perform a job.

      When designing a new training program, or preparing to instruct an employee in an unfamiliar procedure or system, a job analysis can be developed by examining engineering data on new equipment or the safety data sheets on unfamiliar substances. The content of the specific Federal or State OSHA standards applicable to a business can also provide direction in developing training content. Another option is to conduct a Job Hazard Analysis (see OSHA 3071, same title, 1987). This is a procedure for studying and recording each step of a job, identifying existing or potential hazards, and determining the best way to perform the job in order to reduce or eliminate the risks. Information obtained from a Job Hazard Analysis can be used as the content for the training activity.

      If an employee's learning needs can be met by revising an existing training program rather than developing a new one, or if the employee already has some knowledge of the process or system to be used, appropriate training content can be developed through such means as:

      1. Using company accident and injury records to identify how accidents occur and what can be done to prevent them from recurring.

      2. Requesting employees to provide, in writing and in their own words, descriptions of their jobs. These should include the tasks performed and the tools, materials and equipment used.

      3. Observing employees at the worksite as they perform tasks, asking about the work, and recording their answers.

      4. Examining similar training programs offered by other companies in the same industry, or obtaining suggestions from such organizations as the National Safety Council (which can provide information on Job Hazard Analysis), the Bureau of Labor Statistics, OSHA-approved State programs, OSHA full-service Area Offices, OSHA-funded State consultative programs, or the OSHA Office of Training and Education.

      The employees themselves can provide valuable information on the training they need. Safety and health hazards can be identified through the employees' responses to such questions as whether anything about their jobs frightens them, if they have had any near-miss incidents, if they feel they are taking risks or if they believe that their jobs involve hazardous operations or substances.

      Once the kind of training that is needed has been determined, it is equally important to determine what kind of training is not needed. Employees should be make aware of all the steps involved in a task or procedure, but training should focus on those steps on which improved performance is needed. This avoids unnecessary training and tailors the training to meet the needs of the employees.

    3. Identifying Goals and Objectives

      Once the employees' training needs have been identified, employers can then prepare objectives for the training. Instructional objectives, if clearly stated, will tell employers what they want their employees to do, to do better, to stop doing.

      Learning objectives do not necessarily have to be written, but in order for the training to be as successful as possible, clear and measurable objectives should be thought-out before the training begins. For an objective to be effective it should identify as precisely as possible what the individuals will do to demonstrate what they have learned, or that the objective has been reached. They should also describe the important conditions under which the individual will demonstrate competence and define what constitutes acceptable performance.

      Using specific, action-oriented language, the instructional objectives should describe the preferred practice or skill and its observable behavior. For example, rather than using the statement: "The employee will understand how to use a respirator" as an instructional objective, it would be better to say: "The employee will be able to describe how a respirator works and when it should be used." Objectives are most effective when worded in sufficient detail that other qualified persons can recognize when the desired behavior is exhibited.

    4. Developing Learning Activities

      Once employers have stated precisely what the objectives for the training program are, then learning activities can be identified and described. Learning activities enable employees to demonstrate that they have acquired the desired skills and knowledge. To ensure that employees transfer the skills or knowledge from the learning activity to the job, the learning situation should simulate the actual job as closely as possible. Thus, employers may want to arrange the objectives and activities in a sequence which corresponds to the order in which the tasks are to be performed on the job, if a specific process is to be learned. For instance, if an employee must learn the beginning processes of using a machine, the sequence might be (1) to check that the power source is connected, (2) to ensure that the safety devices are in place and are operative, (3) to know when and how to throw the switch, and so on.

      A few factors will help to determine the type of learning activity to be incorporated into the training. Once aspect is the training resources available to the employer. Can a group training program that uses an outside trainer and film be organized, or should the employer personally train the employees on a one-to-one basis? Another factor is the kind of skills or knowledge to be learned. Is the learning oriented toward physical skills (such as the use of special tools) or toward metal processes and attitudes? Such factors will influence the type of learning activity designed by employers. The training activity can be group-oriented, with lectures, role play, and demonstrations; or designed for the individual as with self-paced instruction.

      The determination of methods and materials for the learning activity can be as varied as the employer's imagination and available resources will allow. The employer may want to use charts, diagrams, manuals, slides, films, viewgraphs (overhead transparencies), videotapes, audio tapes, or simply blackboard and chalk, or any combination of these and other instructional aids. Whatever the method of instruction, the learning activities should be developed in such a way that the employees can clearly demonstrate that they have acquired the desired skills or knowledge.

    5. Conducting the Training

      With the completion of the steps outlined above, the employer is ready to begin conducting the training. To the extent possible, the training should be presented so that its organization and meaning are clear to the employees. To do so, employers or supervisors should (1) provide overviews of the material to be learned; (2) relate, wherever possible, the new information or skills to the employee's goals, interests, or experience; and (3) reinforce what the employees learned by summarizing the program's objectives and the key points of information covered. These steps will assist employers in presenting the training in a clear, unambiguous manner.

      In addition to organizing the content, employers must also develop the structure and format of the training. The content developed for the program, the nature of the workplace or other training site, and the resources available for training will help employers determine for themselves the frequency of training activities, the length of the sessions, the instructional techniques, and the individual(s) best qualified to present the information.

      In order to be motivated to pay attention and learn the material that the employer or supervisor is presenting, employees must be convinced of the importance and relevance of the material. Among the ways of developing motivation are (1) explaining the goals and objectives of instruction; (2) relating the training to the interests, skills, and experiences of the employees; (3) outlining the main points to be presented during the training session(s); and (4) pointing out the benefits of training (e.g., the employee will be better informed, more skilled, and thus more valuable both on the job and on the labor market; or the employee will, if he or she applies the skills and knowledge learned, be able to work at reduced risk).

      An effective training program allows employees to participate in the training process and to practice their skills or knowledge. This will help to ensure that they are learning the required knowledge or skills and permit correction if necessary. Employees can become involved in the training process by participating in discussions, asking questions, contributing their knowledge and expertise, learning through hands-on experiences, and through role-playing exercises.

    6. Evaluating Program Effectiveness

      To make sure that the training program is accomplishing its goals, an evaluation of the training can be valuable. Training should have, as one of its critical components, a method of measuring the effectiveness of the training. A plan for evaluating the training session(s) should be developed when the course objectives and content are developed. It should not be delayed until the training has been completed. Evaluation will help employers or supervisors determine the amount of learning achieved and whether an employee's performance has improved on the job. Among the methods of evaluating training are:

      1. Student opinion. Questionnaires or informal discussions with employees can help employers determine the relevance and appropriateness of the training program.

      2. Supervisors' observations. Supervisors are in good positions to observe an employee's performance both before and after the training and note improvements or changes; and,

      3. Workplace improvements. The ultimate success of a training program may be changes throughout the workplace that result in reduced injury or accident rates.

      However it is conducted, an evaluation of training can give employers the information necessary to decide whether or not the employees achieved the desired results, and whether the training session should be offered again at some future date.

    7. Improving the Program

      If, after evaluation it is clear that the training did not give the employees the level of knowledge and skill that was expected, then it may be necessary to revise the training program or provide periodic retraining. At this point, asking questions of employees and of those who conducted the training may be of some help. Among the questions that could be asked are (1) Were parts of the content already known and, therefore, unnecessary? (2) What material was confusing or distracting? (3) Was anything missing from the program? (4) What did the employees learn, and what did they fail to learn?

      It may be necessary to repeat steps in the training process, that is, to return to the first steps and retrace one's way through the training process. As the program is evaluated, the employer should ask:

      1. If a job analysis was conducted, was it accurate?

      2. Was any critical feature of the job overlooked?

      3. Were the important gaps in knowledge and skill included?

      4. Was material already known by the employees intentionally omitted?

      5. Were the instructional objectives presented clearly and concretely?

      6. Did the objectives state the level of acceptable performance that was expected of employees?

      7. Did the learning activity simulate the actual job?

      8. Was the learning activity appropriate for the kinds of knowledge and skills required on the job?

      9. When the training was presented, was the organization of the material and its meanings made clear?

      10. Were the employees motivated to learn?

      11. Were the employees allowed to participate actively in the training process?

      12. Was the employer's evaluation of the program thorough?

      A critical examination of the steps in the training process will help employers to determine where course revision is necessary.

  3. Matching Training to Employees

    While all employees are entitled to know as much as possible about the safety and health hazards to which they are exposed, and employers should attempt to provide all relevant information and instruction to all employees, the resources for such an effort frequently are not, or are not believed to be, available. Thus, employers are often faced with the problem of deciding who is in the greatest need of information and instruction.

    One way to differentiate between employees who have priority needs for training and those who do not is to identify employee populations which are at higher levels of risk. The nature of the work will provide an indication that such groups should receive priority for information on occupational safety and health risks.

    1. Identifying Employees at Risk

      One method of identifying employee populations at high levels of occupational risk (and thus in greater need of safety and health training) is to pinpoint hazardous occupations. Even within industries which are hazardous in general, there are some employees who operate at greater risk than others. In other cases the hazardousness of an occupation is influenced by the conditions under which it is performed, such as noise, heat or cold, or safety or health hazards in the surrounding area. In these situations, employees should be trained not only on how to perform their job safely but also on how to operate within a hazardous environment.

      A second method of identifying employee populations at high levels of risk is to examine the incidence of accidents and injuries, both within the company and within the industry. If employees in certain occupational categories are experiencing higher accident and injury rates than other employees, training may be one way to reduce that rate. In addition, thorough accident investigation can identify not only specific employees who could benefit from training but also identify company-wide training needs.

      Research has identified the following variables as being related to a disproportionate share of injuries and illnesses at the worksite on the part of employees:

      1. The age of the employee (younger employees have higher incidence rates).

      2. The length of time on the job (new employees have higher incidence rates).

      3. The size of the firm (in general terms, medium-sized firms have higher incidence rates than smaller or larger firms).

      4. The type of work performed (incidence and severity rates vary significantly by Standard Industrial Classification, or SIC Code).

      5. The use of hazardous substances (by SIC Code).

      These variables should be considered when identifying employee groups for training in occupational safety and health.

      In summary, information is readily available to help employers identify which employees should receive safety and health information, education and training, and who should receive it before others. Employers can request assistance in obtaining information by contacting such organizations as OSHA area Offices, the Bureau of Labor Statistics, OSHA-approved State Programs, State on-site consultation programs, the OSHA Office of Training and Education, or local safety councils.

    2. Training Employees at Risk

      Determining the content of training for employee populations at higher levels of risk is similar to determining what any employee needs to know, but more emphasis is placed on the requirements of the job and the possibility of injury. One useful tool for determining training content from job requirements is the Job Hazard Analysis described earlier. This procedure examines each step of a job, identifies existing or potential hazards, and determines the best way to perform the job in order to reduce or eliminate the hazards. Its key elements are:

      1. job description;

      2. job location;

      3. key steps (preferably in the order in which they are performed);

      4. tools, machines and materials used;

      5. actual and potential safety and health hazards associated with these key job steps; and,

      6. safe and healthful practices, apparel, and equipment required for each job step.

  4. Conclusions

    In an attempt to assist employers with their occupational health and safety training activities, OSHA has developed a set of training guidelines in the form of a model. This model is designed to help employers develop instructional programs as part of their total education and training effort. The model addresses the questions of who should be trained, on what topics, and for what purposes. It also helps employers determine how effective the program has been and enables them to identify employees who are in greatest need of education and training. The model is general enough to be used in any area of occupational safety and health training, and allows employers to determine for themselves the content and format of training. Use of this model in training activities is just one of many ways that employers can comply with the OSHA standards that relate to training and enhance the safety and health of their employees.