Introduction
Training
is an integral part of your Hearing Conservation Program,
as described in the Overview section. Employee training
is an integral part of any effective safety and health program.
In the Hearing Conservation Amendment included in OSHA's
General Industry Standard 1910.95, each employer must institute
a training program for all employees exposed to noise at or
above the Action Level of 85 dBA as a time-weighted average.
The training must be repeated annually for each employee in
the program. OSHA's Construction Standard 1926.52 requires
employers to administer a "continuing, effective hearing
conservation program". In this standard, 1926.21
(b)(2) also requires construction employers to instruct each
employee to recognize and avoid unsafe conditions, and to
train them about applicable regulations to control or eliminate
hazards or exposure to illness or injury. This includes
training in the hazards of noise and the hearing conservation
program.
The following topics must be covered in any hearing conservation
training program:
- The effects of noise on hearing;
- The purpose of hearing protectors, the advantages, disadvantages,
and attenuation of various types;
- Instructions on selection, fitting, use, and care of hearing
protectors; and,
- The purpose of audiometric testing, and an explanation
of the test procedures.
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Setting Up The Training Program
The following sections illustrate how a typical training program
might be designed. Following this section is a non-mandatory
training guide developed by OSHA for conducting any effective
training program. Using this information, employers
can develop effective training programs that achieve the objective
of the OSHA Noise Standard.
Know the Provisions of the OSHA Noise Standard
- Be familiar with the requirements of the standard.
- Be familiar with the contents of the Hearing Conservation
Amendment.
Identify Employees to be Trained
- Evaluate employee exposures to noise.
- Determine training needs based on noise exposure levels
and the number of employees exposed above exposure limits.
- Determine appropriate method to train new employees
and supervisors.
- Determine appropriate method to conduct annual refresher
training for employees
included in the training program.
Instruct Employees on the Hazardous Effects
of Excessive Noise Exposure
- Review training materials to borrow, lease or purchase.
Effective audiovisual materials are available to cover
the adverse effects of noise on hearing.
- Contact your audiometric testing service, insurance
carrier, or safety and health training materials suppliers
for available employee training materials or handouts.
Instruct Employees on How to Use Hearing Protection
Devices
- Explain the purpose of hearing protection.
- Review the types of hearing protectors available for
use in the areas where the employees are located.
- Describe the advantages and disadvantages of each type
of HPD. (This is discussed in the Hearing
Protection Devices section).
- Define "attenuation" and review the attenuation
for each type of HPD provided. (Refer to the Hearing
Protection Devices section and Appendix B of 1910.95
for more information on hearing protector attenuation
and Noise Reduction Ratings).
- Review methods for selecting, using, and fitting hearing
protection devices. (Refer to the Hearing
Protection Devices section and contact your HPD supplier
and audiometric testing service for additional information
or training resources).
- Review the methods to care for and maintain the available
HPDs. Describe methods for replacing disposable
HPDs.
Instruct Employees about the Audiometric Testing
Program
- Review available training material options. Audiovisual
materials that explain the purpose of audiometric testing
are available for purchase or lease.
- Explain the purpose of baseline audiometric testing.
- Explain the purpose of annual audiograms.
Review Existing Methods of Controlling Noise
Exposures
- Engineering Controls: changes in machinery,
work operations, or plant layout that reduce or eliminate
the hazard (e.g., sound absorbing room treatments, enclosures,
barriers, vibration isolation, damping, silencers and
mufflers, etc.
- Administrative Controls: employee rotation
or cessation of noisy work.
- Personal Protective Equipment: hearing
protection devices.
Keep a Record of Employee/Supervisor Training
- Follow-up and evaluate your training program to make
sure employees know how to protect themselves from excessive
exposure to noise and are using and applying the training
you have given them.
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Voluntary Training Guidelines
I. 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.
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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.
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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.
II. Training Guidelines
OSHA's training guidelines follow a model that consists
of:
- Determining if Training is Needed
- Identifying Training Needs
- Identifying Goals and Objectives
- Developing Learning Activities
- Conducting the Training
- Evaluating Program Effectiveness
- 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.
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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.
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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:
- Using company accident and injury records to identify
how accidents occur and what can be done to prevent
them from recurring.
- 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.
- Observing employees at the worksite as they perform
tasks, asking about the work, and recording their
answers.
- 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.
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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.
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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.
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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.
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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:
- Student opinion. Questionnaires
or informal discussions with employees can help employers
determine the relevance and appropriateness of the
training program.
- 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,
- 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.
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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:
- If a job analysis was conducted, was it accurate?
- Was any critical feature of the job overlooked?
- Were the important gaps in knowledge and skill included?
- Was material already known by the employees intentionally
omitted?
- Were the instructional objectives presented clearly
and concretely?
- Did the objectives state the level of acceptable
performance that was expected of employees?
- Did the learning activity simulate the actual job?
- Was the learning activity appropriate for the kinds
of knowledge and skills required on the job?
- When the training was presented, was the organization
of the material and its meanings made clear?
- Were the employees motivated to learn?
- Were the employees allowed to participate actively
in the training process?
- 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.
III. 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.
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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:
- The age of the employee (younger employees have
higher incidence rates).
- The length of time on the job (new employees have
higher incidence rates).
- The size of the firm (in general terms, medium-sized
firms have higher incidence rates than smaller or
larger firms).
- The type of work performed (incidence and severity
rates vary significantly by Standard Industrial Classification,
or SIC Code).
- 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.
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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:
- job description;
- job location;
- key steps (preferably in the order in which they
are performed);
- tools, machines and materials used;
- actual and potential safety and health hazards associated
with these key job steps; and,
- safe and healthful practices, apparel, and equipment
required for each job step.
IV. 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.
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