Certified Safety Health Manager Examination Preparation Training (CSHM)

Developing a Safety Training Program

What is a program?

A "program" contains a written plan, policies, processes, procedures, rules, forms, reports, and possibly other documents. A safety training program is just one of many interactive programs integrated into a safety management system. In order to meet the continuing need for highly trained safety and health staff, it's important to develop a safety training program that includes a written plan for training new-hire and current employees whenever they are introduced to new hazards.

What is the purpose of a safety training program?

The purpose of a training plan is to provide training professionals with clearly written policy and guidelines for implementing an effective safety education and training program for employees.

The plan should contain elements that are informative and directive.
It should inform everyone about the safety training mission, policies, procedures
It should also clearly state who is responsible for carrying out the mission, policies and procedures

ANSI Z490.1-2001 Elements of a Safety Training Program

According to ANSI 490.1-2001, at a minimum a training program should include:

A development piece, including needs assessment, learning objectives, course content and format, resource materials, and criteria for course completion
Delivery by competent trainers in a suitable training environment
Evaluation in a continuous improvement system
Documentation and recordkeeping
A plan describing how the various training elements will be accomplished

OSHA's Suggested Training Plan Core Elements

The following information was adapted from 29 CFR 1910.120 App E, Training Curriculum Guidelines - (Non-mandatory). Although written specifically for training hazardous waste operations, the core criteria may serve as an excellent template for the design of your safety training program. There are 10 core criteria:

1. Training facility. The training facility should have available sufficient resources, equipment, and site locations to perform didactic and hands-on training when appropriate. Training facilities should have sufficient organization, support staff, and services to conduct training in each of the courses offered.

2. Training Director. Each training program should be under the direction of a training director who is responsible for the program. The Training Director should have a minimum of two years of employee education experience.

3. Instructors. Instructors should be deemed competent on the basis of previous documented experience in their area of instruction, successful completion of a "train-the-trainer" program specific to the topics they will teach, and an evaluation of instructional competence by the Training Director. Instructors should be required to maintain professional competency by participating in continuing education or professional development programs or by completing successfully an annual refresher course and having an annual review by the Training Director. The annual review by the Training Director should include observation of an instructor's delivery, a review of those observations with the trainer, and an analysis of any instructor or class evaluations completed by the students during the previous year.

4. Course materials. The Training Director should approve all course materials to be used by the training provider. Course materials should be reviewed and updated at least annually. Materials and equipment should be in good working order and maintained properly. All written and audio-visual materials in training curricula should be peer reviewed by technically competent outside reviewers or by a standing advisory committee. Reviews should possess expertise in the following disciplines were applicable: occupational health, industrial hygiene and safety, chemical/environmental engineering, employee education, or emergency response. One or more of the peer reviewers should be a employee experienced in the work activities to which the training is directed.

5. Students. The program for accepting students should include:

Assurance that the student is or will be involved in work where chemical exposures are likely and that the student possesses the skills
necessary to perform the work.
A policy on the necessary medical clearance.

6. Ratios. Student-instructor ratios should not exceed 30 students per instructor. Hands-on activity requiring the use of personal protective equipment should have instructor ratios of 5-10 students per instructor.

7. Proficiency assessment. Proficiency should be evaluated and documented by the use of a written assessment and a skill demonstration selected and developed by the Training Director and training staff. The assessment and demonstration should evaluate the knowledge and individual skills developed in the course of training. The level of minimum achievement necessary for proficiency shall be specified in writing by the Training Director. If a written test is used, there should be a minimum of 50 questions. If a written test is used in combination with a skills demonstration, a minimum of 25 questions should be used. If a skills demonstration is used, the tasks chosen and the means to rate successful completion should be fully documented by the Training Director. The content of the written test or of the skill demonstration shall be relevant to the objectives of the course. The written test and skill demonstration should be updated as necessary to reflect changes in the curriculum and any update should be approved by the Training Director. The proficiency assessment methods, regardless of the approach or combination of approaches used, should be justified, documented and approved by the Training Director. The proficiency of those taking the additional courses for supervisors should be evaluated and documented by using proficiency assessment methods acceptable to the Training Director. These proficiency assessment methods must reflect the additional responsibilities borne by supervisory personnel in hazardous waste operations or emergency response.

8. Course certificate. Written documentation should be provided to each student who satisfactorily completes the training course.

The documentation should include:

a. Student's name.
b. Course title.
c. Course date.
d. Statement that the student has successfully completed the course.
e. Name and address of the training provider.
f. An individual identification number for the certificate.
g. List personal protective equipment used by the student.

This documentation may include a certificate and an appropriate wallet-sized laminated card with a photograph of the student and the above information. When such course certificate cards are used, the individual identification number for the training certificate should be shown on the card.

9. Recordkeeping. Training providers should maintain records listing the dates courses were presented, the names of the individual course attendees, the names of those students successfully completing each course, and the number of training certificates issued to each successful student. These records should be maintained for a minimum of five years after the date an individual participated in a training program offered by the training provider. These records should be available and provided upon the student's request or as mandated by law.

10. Program quality control. The Training Director should conduct or direct an annual written audit of the training program. Program modifications to address deficiencies, if any, should be documented, approved, and implemented by the training provider. The audit and the program modification documents should be maintained at the training facility.

The Two-Level Training Model

If you review OSHA Publication 2254, Training Requirements in OSHA Standards and Training Guidelines, you'll discover that over 100 safety and health standards require some form of training. Most of that training requires or infers some form of evaluation occur to make sure employees have the KSA's necessary to perform their jobs safely.

With this in mind, it makes sense to develop a training model that works to ensure you meet OSHA criteria and ANSI/ASSE Z490.1-2001 guidelines. Consequently, we'll introduce you to a two-level training model that "fits" OSHA requirements and evaluation criteria.

Later in the course, we'll take a look at how to effectively evaluate the learner and your training program using a five-level evaluation approach recommended in the ANSI/ASSE Z490.1-2001 guidelines. Now, don't let the fact that there are five levels of evaluation worry or confuse you here. In this course we discuss the first three levels of evaluation because they measure the impact of training on the learner (OSHA's primary interest). Level four and five evaluation measures the impact of training on the organizations productivity and profitability.

Level One: General Safety Training

One of the most important questions you'll ask when developing safety training is whether OSHA requires some sort of "demonstration" (test, evaluation) of employee knowledge and skills. If OSHA Standards do not require employer evaluation of employee performance, Level One general safety training may be just fine in meeting your training needs. Although general safety training may be effective when presenting mandatory and "nice to know" information, it will not be acceptable when training includes how to perform hazardous procedures and practices.

For example, a typical general safety training presentation might include:

an overview of employer and employee responsibilities
principles of root cause analysis
introduction to the elements of our safety management system
safety leadership principles
introduction to the Employee Assistance Program
engineering control basics

A typical training session might include watching a video about common hazards in the workplace or participating in some form of discussion or group activities. Employees may actually learn how to do something, but they won't have to prove it to anyone. A simple attendance roster might suffice to document Level One training. To get the course completion certificate, all you need do is attend. The only evaluation technique required is the reaction survey.

Level Two: Technical Safety Training

As stated earlier, Level Two technical training is a how-to experience. Because OSHA requires that employees be trained to gain adequate knowledge and skills to perform specific procedures and practices before they are exposed to hazards, Level Two technical training is the most common form presented in the workplace. The training may be quite specific and usually requires some form of hands-on participation or practice. In addition, evaluation of student performance in the learning environment is required.

For instance, in 29 CFR 1910.132 Personal protective equipment(PPE), we read the following about personal protective equipment training:

1910.132(f)(1). Train workers who use PPE. Training must cover the following:

When PPE is necessary
What PPE is necessary
How to put on, remove, adjust, and wear PPE
The limitations of PPE
Care, maintenance, and disposal of PPE

Each worker must understand the training and demonstrate the ability to use PPE properly. Workers must be retrained when they can’t demonstrate required skills and when there are changes in the workplace or the PPE that make previous training obsolete.

Whenever you read the term "demonstrate" or "how to" in OSHA standards, or whenever you must train a hazardous procedure or practice, you'll be required to evaluate the employee's ability to perform within the learning environment before exposure to actual hazards. Tip: Even if the rules don't specifically require employees to demonstrate skills, it's smart to require employees to prove proficiency by performing some kind of hands-on skills demonstration.

To earn the course certificate in Level Two technical training, the learner must pass a test (preferably written) and/or skills demonstration in the learning environment. When the student completes the course they may be considered at least "initially qualified" to perform procedures and practices. To document the training, the trainer and learners will jointly certify completion of training. Examples of Level Two technical training include:

respirator training
conducting a safety inspection
permit-required confined space entry
emergency evacuation procedures
lockout-Tagout procedures

Bottom line: If it's a "how to," it's Level Two!

Management involvement in training

First-line supervisors play a crucial role in safety and health protection because of their immediate responsibility for workers and for the work being performed. Effective training of supervisors will address their safety and health management responsibilities as well as information on hazards, hazard prevention, and response to emergencies. Although they may have other safety and health responsibilities, those listed in these guidelines merit particular attention.

Ensure managers understand their safety and health responsibilities so that they will effectively carry out those responsibilities. Because there is a tendency in some organizations to consider safety and health a staff function and to neglect the training of managers in safety and health responsibilities, the importance of managerial training is noted separately. Managers who understand both the way and the extent to which effective safety and health protection impacts the overall effectiveness of the organization itself are far more likely to ensure that the necessary safety and health management systems operates as needed.

Source: OTN, Steven Geigle, M.A., CSHM

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Disclaimer: This material is for training purposes only. Its purpose is to inform employers of best practices in occupational safety and health and general OSHA compliance requirements. This material is not, in any way, a substitute for any provision of the Occupational Safety and Health Act of 1970 or any standards issued by OSHA.