The Safety Corner: Safety Training

Re-evaluating the plans often as a team will ensure that gaps in the plans are recognized and fixed. This becomes a living document, where constant assessment and correction become the norm to refine the plans as time progresses. This is especially true when near-misses or incidents occur. Working with safety and risk management professionals to accomplish this process can be a good idea, as outside expertise can bring a fresh set of eyes and experienced evaluation tools to the table. By assessing past injury and illness losses, workers’ compensation experience modification rates, job site assessments, and a thorough examination of the hierarchy of controls, consultants can often yield great results and help to fill in potential holes in the plans.

MSHA Requirements

Written plans and formal safety training programs are also a regulatory requirement. Both the Occupational Safety and Health Administration (OSHA) and the Mining Safety and Health Administration (MSHA) require formal training and written plans depending on the scope of work.

MSHA has arguably more stringent requirements for training and written safety plans. Each mine type, sand and gravel (deemed “Part 46”), and underground and surface mines (deemed “Part 48”), has different training requirements. For surface and underground mines, MSHA requires a pre-approved written training plan that “contains effective programs for training new miners and newly hired experienced miners, training miners for new tasks, annual refresher training, and site-specific hazard awareness training.” It further requires “a general description of the teaching methods and the course materials that are to be used in the training program, including the subject areas to be covered and the approximate time or range of time to be spent on each subject area.” Trainers must also be pre-approved by MSHA. Surface sand and gravel mines also require training plans that are “approved upon submission” and only require a Competent Person to instruct the programs.

All MSHA courses cover miners’ rights, recognizing and reporting hazards, work duties, transportation and communication, escape and emergency evacuation plans, fire warning and firefighting, and other requirements as dictated by Federal Code. Part 46 miners are required to have an initial training of 24 hours, with eight additional hours at the mine site. Part 48 miners have a required 32 hours of initial training, with an additional eight hours at the mine site. Additionally, all miners have annually required eight-hour refresher training. These trainings and written safety plans are reviewed at the two required annual inspections that occur each year across Alaska.

OSHA Requirements

OSHA, by comparison, does not have a specified requirement to visit any workplace twice a year like MSHA, has only a limited number of required safety plans, and few requirements for who can train employees on safety. OSHA’s training requirements depend on the Subpart of the Code of Federal Regulations, but the training must be completed by a “Competent Person” or a “Qualified Person” depending on the Subpart. A Competent Person for training purposes is defined as, “knowledgeable of applicable standards, is capable of identifying workplace hazards relating to the specific operation and has the authority to correct them.” In addition, there are some standards that add additional specific requirements which must be met by the competent person. A Qualified Person is defined as a person who, “by possession of a recognized degree, certificate, or professional standing, or who by extensive knowledge, training, and experience, has successfully demonstrated his ability to solve or resolve problems relating to the subject matter, the work, or the project.” Examples of Subparts that require training by a Qualified Person include fall protection and scaffolding.

OSHA has a number of regulations that require mandatory training of workers prior to the start of work. Some examples are exit routes and emergency planning, fire prevention plans, personal protective equipment, and personal fall arrest systems. Hazard communication, a requirement designed to ensure the safe handling of hazardous chemicals in the workplace, is also required. It continues to be the second most cited Subpart year after year in the OSHA Top 10 violations list behind fall protection. Some sections, such as hazardous waste operations and emergency response, require specific training elements, and include a requirement for an annual refresher.

OSHA 10 and 30 hour courses are training programs designed to educate workers and supervisors on occupational safety and health hazards, available for both construction and general industry. The 10-hour course is for entry-level workers, while the 30-hour course offers more in-depth, comprehensive training for supervisors and those with safety responsibilities. Both are completed through an OSHA-authorized training provider, and successful completion leads to a US Department of Labor card. These specified curriculum programs will ensure that workers receive the needed training for safe working environments and also meet the requirements for regulatory compliance. Trainers who are authorized to instruct these programs must have met OSHA’s requirements for training and evaluation by OSHA approved facilities like universities and also require five years of field experience.

Quality Training

These courses are best delivered in person as opposed to online when practical. While online training might be more flexible and offer some cost savings, the in-person delivery is better for complex questions and discussions with real-time feedback, hands-on practical presentations with equipment, and team building. Companies in Alaska that offer 10- and 30-hour programs should have the ability to travel where the training is needed. While having an instructor come to your region might cost more, it is likely less expensive than sending workers to the city for training. The outcome is the important part, and quality training should be the focus so employees can reduce risks in the workplace.

Measuring the effectiveness of training is a key aspect to a comprehensive safety management plan. While reactive lagging indicators such as a reduction in incident and accident cases, lower experience modification rates, and realized cost savings for compliance and insurance are notable, a move towards the proactive leading indicators is the goal. Leading indicators such as safety audits, near-miss reporting and investigation, and engaged employee involvement better shape the overall safety culture. The best bet is to have a safety management plan that incorporates all the metrics with a goal of protecting workers, increasing productivity and profits, and reducing the total cost of risk. Training is just one piece of a larger safety culture, an ongoing, dynamic process that balances productivity and safety, both of which are essential elements to a successful operation. The bottom line is that a safe workplace is more productive than an unsafe one, and training is an important part of the overall safety program.