Phil La Duke's Blog

Fresh perspectives on safety and Performance Improvement

If A Temp Dies On The Job, Does It Count?


By Phil La Duke

 “There’s a sense that a new guy’s life isn’t worth as much cos he hasn’t put his time in yet.” Chris Taylor, Platoon

“Temp” as in temporary; a temporary person. The designation shows how much value we tend to place on those in the workforce who won’t be around very long. It doesn’t make much sense to throw away money on something you don’t intend to keep, and so it is for the safety of a growing number of temporary workers and contractors who, in the eyes of so many employers (and too many of their safety professionals) don’t count as much as long-term employees.
Increasingly, companies have been out-sourcing the dirtiest, most dangerous jobs to smaller firms and replacing full time workers with contract employees or temporary workers, “temps”.
I urge you to watch the attached youtube video. It tells the story of a young worker, Larry Daquan “Day” Davis, who landed his first job as a temporary worker at a Barcardi plant in Florida. Spoiler alert: he is killed 90 minutes into the first job he has ever had. The video is brief, and it isn’t overly melodramatic and won’t try to manipulate your emotions by tugging at your heart strings.
http://www.youtube.com/watch?v=cNcsTRQNZLE 
Who’s to blame for young “Day” Davis’s life? An executive who refused to invest in a safer workplace? maybe. A plant manager who failed to correct a known hazard? maybe. An over-zealous operations manager who valued production at all costs? maybe. The foreman who sent Davis into harm’s way unsupervised? maybe. The human resource manager who decided that Davis didn’t need adequate training (and before someone sounds off that I don’t KNOW that he had inadequate training, let me just say that if you are placed in a position that can kill you 90 minutes into your first job you probably haven’t been trained well enough. I will even go so far as to say that if you get killed on the job in this way you don’t have the skills to even be on a manufacturing floor, let alone crawling around in a machine’s blind spot.) maybe. Or even an indifferent safety professional who figured he or she had enough to do and didn’t have time to worry about the safety of a “temp”? maybe.  I don’t know that any of these things were true on that fateful August day, but I DO know that these attitudes toward tempory workers and contractors exist in enough workplaces to make this a problem; a big problem.

It Was An Accident
No one, at least so far as can be ascertained, set out to kill young Day Davis on his first day of work, not even two full hours into his first shift on his first job. Never-the-less, Davis died horrifically before he even got his first paycheck. This happened, August 16, 2012, and the fallout wasn’t exactly earth-shattering. OSHA cited Barcardi with 12 violations and recommended a fine of $192,000; the price you pay for ending a young worker’s life. There was no public outcry, no one organized boycotts against Barcardi, no criminal charges were filed; when it comes to temps nobody seems to care all that much. The death of a temp is a shame and little else.
Because Contractors “Don’t Count”

Years ago I was talking to a safety professional about the death of a contractor at one of the facilities for which he was responsible. When I asked about the fatality he said, “it was a contractor, so it didn’t count” he said before catching himself. I won’t beat up on him, he felt worse about the death than a lot of people would have, but his immediate reaction is telling. We as safety professionals (and companies) have become so concerned with measurements and statistics that we are losing touch with the human side of safety. When our first reaction at the death or serious injury of a contractor is relief that it doesn’t count against our body count we have lost our way; we are seriously out of touch with all the safety slogans, and philosophies, and zero-injury goals that plaster the wall.
It’s easy to see how the idea that contractors and temps “don’t count” developed. Laws against “co-employment” muddy the waters regarding just who may be legally trained without violating the tax code and who may not. For the record, as I understand it, employers have a shared responsibility for training temporary workers and contractors on safety. What then, constitutes safety training? I doubt that Day received the basic training required by law, given that he was killed less than two hours into his career, but suppose he had? Would Hazard Communication and Right-To-Know or some hackneyed safety orientation have saved him? I doubt it. But if he had been given training such that he would have understood how the equipment worked and what it did he might have recognized the dangers and been able to save his life.
The Client-Company Must Step Up
Too often companies hire contractors and hope for the best, when it comes to worker safety. They count on the employers of record to meet the government standards for safety, but too often the contract house or temp agency lacks the resources to provide adequate training to their workers, and many and more couldn’t care less. The contract employment business is a cut-throat industry where clients squeeze margins tighter and tighter and temps and contractors are increasingly forced to cut costs just to survive. What’s more, many contractors have few enough employees that many government regulations may not apply to them. The end result is that increasingly, young workers, immigrants, and working poor are put at severe risk.
While I don’t let the temp agencies and contract houses off the hook they don’t often know the specific working conditions in which one of their workers will be placed. In many cases, minimally trained recruiters race against the clock to get workers placed in their client’s facilities. And the worse the safety of the client the higher the turn over, creating a churning of workers; it’s a perfect situation for disaster.
It’s A Matter of Ethics
Some will argue that temp workers and contractors fill a valuable niche and that some industries would be unable to compete were it not for these workers. I say that companies who employ temps to avoid becoming employers of record, or who churn employees every 89 days to prevent them from becoming full time, or who otherwise look for the cheapest labor and balk at even the smallest investment in safety should be run out of the business.  Many temps work in a climate of fear so pervasive that the merest mention of a reluctance to work in an unsafe situation brings the threat of dismissal.  A worker (not a temp) once told me, that we have to get our safety under control or the company will move our jobs to a country that doesn’t care about safety, but in the minds of temps they already live in  a country that doesn’t care about their safety.

If You Don’t Act Who Will?

Before you dismiss this as more of my ranting and outrageous provocation consider the fate of your children, or grandchildren as they enter the workforce desperate for work and grateful for their first jobs. Imagine your pride as you see them go off to what will be the first step towards a long and successful career, and then imagine them dead on a filthy factory floor, crushed to death like Day Davis. Imagine them killed, because in the minds of too many employers they were nothing more than temps, who, after all, just don’t matter.

p.s. Bacardi’s fine for the death of Day Davis was since reduced by $80,000; temp agency fine was $0.

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Can OSHA Survive the Fiscal Cliff?


By Phil La Duke

Two debates rage these days, one regarding the most appropriate response to the so-called fiscal cliff, and the other concerning the effectiveness and the continued need for worker safety regulations.  The convergence of these two debates makes the future of the Occupational Safety and Health Act (OSHA) both as a law and as an enforcement agency.

For some, the real question is not “will OSHA survive?” but “should it?” The lessons of the rapacious deregulation—the housing crisis, the orgy of banking abuses, and the rape of the poor resultant from usurious payday loan businesses—go largely unlearned or ignored, by those who argue that OSHA is an anachronism.  In effective and bloated, they assert, it’s time for OSHA to go.

For others, OSHA is a sacred cow; to even suggest that OSHA needs to be reorganized is blasphemy. In their minds to dismantle OSHA is tantamount to abandoning safety to the unscrupulous businesses that use workers like chattel.  Without OSHA, they argue, a hundred years of safety will be unceremoniously unraveled.

Both the debate over the fiscal cliff and over the need for, and relevance of, safety regulations, belie deeper conflicts; both are expressions over values.  In the case of the fiscal cliff debates people are arguing if things we as a society are worth the money we currently spending on them, in other words, are we getting our money’s worth for the things we collectively purchase. For many, this debate is about a very basic principle: the role of government.  Some see the fiscal crisis as a golden opportunity to significantly reduce big government, while others see it as an essential battle to defend decades of social advancement. Add to this debate, international controversy surrounding whether or not safety requirements have become excessive and overly burdensome. At the heart of this debate is whether or not we believe that business, left to its own designs, will do the right thing in terms of protecting workers.

I won’t take a side in these debates, but I will say that OSHA is likely to be the big loser.  To some degree OSHA has been the victim of its own success. We just don’t see disasters on the scale of the Triangle Shirt Waist fire anymore.  The success of safety regulation and enforcement has created a global public opinion (far from the consensus, but with enough sympathizers to make it significant) that the workplace is safe enough, and even if isn’t there is scarce little that government can do about it.

OSHA currently lacks the resources to do much more than to respond to complaints.  It offers a myriad of valuable free services that most businesses refuse to use. I have actively promoted OSHA’s free products and services among my customers to whom I consult only to be told that I was crazy if I thought they were going to invite OSHA into their facilities. Each one ended up paying me to do what they could have received free from OSHA. If OSHA is to survive, it needs to proactively cut funding for VPP, training, and its other highly valuable and disappointingly under-used programs and reallocate a portion of the monies saved to investigation and enforcement. Doing so will not only create public good-will as it sees OSHA as actively participating in cost reduction; it will also raise public awareness of the programs.  Increased funding for enforcement will likely bring to light the true state of safety in business today.  Perhaps there will be public outcry at widespread abuses by business or perhaps it will confirm what many believe: that business in America today value safety and do a good job protecting workers. In either event, the public good is served.

For the many of the great unwashed (and uninformed) have been swayed by campaign ads that safety costs jobs. Politicians play free and lose with insinuations that workers had better toughen up and decide whether they want to safe at work or to be unemployed. And if safety costs jobs, it follows that OSHA is a government agency dedicated to eliminating jobs, forcing high-paying low-skill jobs off shores where foreigners do the jobs for pennies on the dollar. If you believe that OSHA does this then you believe that the government is essentially spending your tax dollars to screw you out of your livelihood. Forget whether or not OSHA can survive in this environment and worry can America survive in this environment.

Safety professionals haven’t helped OSHA’s cause.  The propagation of the belief that 90% (or more) of safety is behavioral has created (in addition to a cottage industry of snake-oil salesmen) a belief that OSHA is useless—after all, why have a government agency devoted to ensuring safety by dealing with only 10% or less with the things that actually cause injuries[1] when you can just kick the stupid, lazy, and careless workers in the ass? If one believes that the secret to a safer workplace lies in behavior modification, recognition and reward, and other carrot-and-stick policies that what relevancy does OSHA have? Would we expect OSHA inspectors to audit for motivation? Would it establish standards for recognition and reward?

For many people, OSHA is a vestige of days gone by. They no longer feel the pain of losing loved ones in the workplace and have convinced themselves that it can never happen again. If OSHA hopes to survive (in any meaningful and useful sense, let’s face it there isn’t a politician alive with the gut and gumption to truly end OSHA, but there is a fair chance that it will become so emasculated and underfunded that it will cease to be more than hollow symbol. If OSHA is going to survive and thrive it will have to reinvent itself even if it is only in the public.


[1] For the record I reject the premise that 90% or more of injuries are caused by unsafe behaviors and I understand that OSHA addresses far more than physical hazards and addresses (or seeks to address) behavioral choices through training and awareness.

Filed under: Behavior Based Safety, Phil La Duke, , , , ,

Is Safety Compliance Training A Complete Waste Of Time?


Introduction

U.S. Industry spends a fortune needlessly delivering safety training that fails to engage the learners, provides only the most cursory awareness of the topic, and imparts little in the way of skills. There are exceptions, of course.  A handful of large companies and many international Unions have made a concerted and largely effective effort to meet the requirements imposed by OSHA while ensuring that the training meets very specific needs of the workers. Unfortunately, most employers lack sufficient resources and will to provide professionally designed and developed training that also meets OSHA regulations.  Instead of spending precious resources developing training that is customized to their needs while meeting Federal requirements, these smaller (or less interested) organizations waste their training budgets buying training that is costly, time consuming and boring; the learners don’t like it and employers resent having to provide it.  The situation is a lose-lose proposition except that this kind of training satisfies OSHA regulations that mandate that it be provided.  Many companies find themselves expending precious resources providing safety training for the sole purpose of complying with government regulations that require training.  Most of this training fails to provide the skills it intends to impart, exacts a considerable opportunity cost, and does little to protect workers. By making small changes to how safety training is designed and delivered, however, organizations can comply with Federal safety regulations and significantly increase the instructional integrity and effectiveness of the safety training courses it provides to workers.

And what’s more all parties seem to like things precisely as they are.  There is little in the national debate in the way of a call to change the system. Most people seem to be content with a system that promulgates the existing checklist mentality instead of a system where employers are required to do only that training which directly links to a safer work environment where the risk to workers is significantly reduced. While scarce little resource exists, veteran safety professionals can attest to the woefully inadequate safety training that exists in many organizations throughout the United States.

A Brief History of OSHA Requirements for Safety Training

While the Occupational Safety and Health Act (OSHA) of 1970 itself does not directly specify that employers provide health and safety training it does so indirectly since section 5(a)(2) requires that employers “ . . . shall comply with occupational safety and health standards promulgated under this Act.”  Over the years OSHA has prescribed more than one hundred specific training requirements and while it has developed training guidelines for employers, the development of safety training has largely been relegated to subject matter experts and entrepreneurs (chiefly those with a safety expertise instead of a training background).  Companies are reluctant to develop training that might go beyond mere compliance for fear that if in trusting the task to an instructional designer the resultant courses could cause an organization to expend resources developing a course that, while instructionally sound, might not meet the criteria required by OSHA.  Simply stated, many employers make the pragmatic decision to use a course that meets the letter of the OSHA standard over a superior course that meets the specific skills requirements.

OSHA and ADDIE

If safety training is poorly designed and developed the blame lies not with OSHA. According to OSHA, its training guidelines were designed to assist employers in seven areas: determining whether worksite issues can be resolved by training; determining what training, if any, is needed; identifying goals and objectives for the training; designing learning activities; conducting training; determining the effectiveness of the training; and revising the training program based on feedback from employees, supervisors, and others. In short, OSHA’s guidelines aren’t significantly different from the ADDIE model.  Developed in 1975 the ADDIE model was commissioned by the U.S. Army who contracted the Center for Educational Technology at Florida State University (FSU) in response to a growing disparity between the complexity and sophistication of defense equipment and the diminished educational background of newly recruited service personnel.

The solution proposed by FSU was to create a ‘systems approach’ to training. The five-phase process prescribes a strict, step-by-step approach wherein training is developed by completing an Analysis, Design, Development, Implementation, and Evaluation.  The primary purposes of the Analysis stage aligns closely to OSHA’s first stated purpose of determining whether worksite issues can be resolved by training and if so, what training, if any, is needed. Similarly, the second phase of ADDIE, Design, maps to OSHA’s  goal of helping employers in identifying goals and objectives for the training and designing learning activities. And while ADDIE’s Development phase doesn’t have a counterpart in the OSHA guidelines it his highly unlikely that this incongruence could account for the weakness in today’s safety training.

While the guidelines were intended to “encourage cooperative, voluntary safety and health activities among OSHA, the business community, and workers” the end result was a glut of companies that do a poor job of safety training, the participants rarely retain or apply the things they learn, and except for complying with government regulations little is accomplished. Safety training is required to protect workers so why should organizations have to fight with people to get them to complete the training?

How Do We Know the Training Is Ineffective?

Most of the data that supports the contention that much of the OSHA compliance safety training is ineffective is anecdotal; gathered from my personal experience (over 25 years of providing safety training in a diverse range of manufacturing, healthcare, logistics, construction, and aerospace environments) and from the conclusions of many other professionals with a hands-on awareness of safety training as delivered in industry today.  Anyone who doubts the assertion that safety training is ineffective need only review the course evaluations.  Some of common reasons given for resisting safety training include: the training is boring, the topics presented are just “common-sense” or don’t pertain to learners, and learner only attends the training because he or she was forced to attend – not because they are expected to learn anything useful.

Chief Complaints Of Safety Training

      OSHA required training is unpopular on all fronts.  Organizations view OSHA training as needlessly costly, over-protective, expensive, and unnecessary.  Training professionals view safety training as untouchable—developing custom training may result in training that is high quality but does not meet the OSHA standards.  Employees view the commercially purchased one-size-fits-all safety training as a boring, irrelevant waste of time. The chief problem associated with poor safety training is that a relatively small group of providers have created courses that appeal to the widest customer set.  So while it is true that there is some training tailored to fit a specific audience most is general training aimed at the lowest common denominator.

Safety Training Is Boring

A chief complaint regarding safety training is that it is boring. A large amount of safety training fails to keep the learners engaged in the topics presented. And to make matters worse, a generation of safety trainers has grown up believing that the topics in OSHA-required training are intrinsically boring.  OSHA bears indirect responsibility for the bromidic tone prevalent in safety training.   Employers have been taught by OSHA that they must provide training, but employers never got the message that the training had to be meaningful.  Organizations feel coerced by OSHA into delivering mediocre training with little to no relevance to the specific safety issues that are most likely to injure workers. The belief that training designed to protect an individual from life ending or debilitating injury is somehow boring by default is incredible, and yet millions of workers assume that safety training will automatically put them to sleep.

There are three issues associated with boring safety training: course design, facilitation, and evaluation. Courses are poorly designed because the primary intent of the course is typically nothing more than to meet the OSHA requirements.  Facilitation is often sub par because it is entrusted to subject matter experts instead of professional trainers. If the training is evaluated, this evaluation of the training is typically useless: if OSHA evaluates it at all, it limits its evaluation to a determination as to whether or not the training met the OSHA requirements and not whether or not the training was effective.

Designing Better Safety Training Courses

The best way to make safety more interesting is to develop a good course design, and a good course design beings with good course objectives.  In this regard, OSHA has made it easy for course designers.  In non-safety training it is rare that a course designer is given clear and specific outcomes required, but OSHA clearly defines the criteria for the training to meet the standard.  Unfortunately, OSHA falls short of developing the objectives for the required courses, and instead allows employers significant latitude with their treatment of the required course content. The result tends to be training that is very rudimentary and that focuses on awareness-level learning instead of skills application.

A primary contributor to the issue of over educating at the awareness level is that much of the safety training is developed by Subject Matter Experts in Safety (SMEs) who have little experience in developing training. SMEs often have difficulty separating the “need to know” from the “nice to know” and many SMEs are convinced that a skill can only be acquired once an individual fully grasps the scientific principles behind the skills and has a complete understanding of the topic presented.  These courses bog down in technical minutia that does nothing to increase the proficiency with which the participants will apply the skills being taught. Some may argue that there is no harm in providing extra information, but this is a specious argument.  Sometimes courses contain so much minutia and trivia that the focus on the skills required are lost.

It is unfortunate that OSHA inspectors do not evaluate course objectives. Certainly good course objectives can be a checklist of the topics that the course must cover but they can also identify the criteria for success. The best objectives describe measurable and observable behaviors that could easily be audited by OSHA.  Regrettably, while it is fairly easy for OSHA inspectors to measure what someone can and cannot do, it is nearly impossible to tell what someone knows unless there’s an accompanying observable behavior.

In broad strokes, courses that impart knowledge are “education” and those that teach a skill are “training”; this is a important distinction. Every good instructional objective will have three elements:

1. Identification of the skill expressed using action verbs

2. Criteria for success

3. Measurement parameters

The identification of a skill using action verbs may seem fairly obvious, but when one attempts write an objective that clearly identifies the skills one wants to impart, it can be extremely difficult and frustrating especially for subject matter experts, who while very skilled in safety may lack the most cursory instructional design skills.

Action verbs denote a person doing something, which is important when one is attempting to provide skills training relative to safety because when an organization trains a worker, it generally expects them to DO something. When one writes an objective it is crucial that one uses an action verb to describe what the participants will be able to do.

Establishing a criteria for success also SEEMS easy, but can be even more difficult than describing the skill, but once one has determined the actions the workers will be able to perform one needs to identify how good is “good enough”. This is where OSHA could be a key partner with industry but to date has done little to guide the developers of safety training.  Take Material Safety Data Sheet training, for example.  OSHA could easily identify specific criteria for success that would guide both course developers and government inspectors alike. Knowledge of a hazard without applicable skills for safely interacting with the hazard is useless.  As OSHA develops criteria for the successful achievement of safety training objectives it should resist the temptation of being overly stringent in its expectations. Perfectionists will demand 100% accuracy and that is laudable, but it also sets up an unrealistic expectation and the likelihood that an organization will end up retraining a considerable portion of the population who will never pass with 100% accuracy.   A far more reasonable approach is to allow for provisional completions, i.e. the learner is credited with completing the course provided he or she is able to perform a task with 100% accuracy, OR is able to perform it with 75% task followed by one-on-one coaching.

Facilitation of Safety Training

A lack of professional course design is certainly a problem, but non-engaging content is only part of the problem. In the earnest desire to comply, far too many safety courses focus only on the content and ignore delivery.  Subject Matter Experts turned safety instructors drone on and on, oblivious to a room full of participants who have completely checked-out mentally. A good safety course should keep the learners engaged by employing some simple instructional methods.  OSHA can support this by issuing criteria for certifying instructors.

An unskilled instructor typically struggles to hold the participants’ attention.  Estimates of the attention span of an average adult American range between 10 and 15 minutes.   That may seem hard to believe until one considers the way the brain works.  The human brain takes in information for about 30 seconds and then spends about a minute and a half processing the information. This cycle continues until the brain feels the stress of concentration and moves on to a new subject. These times are purely to demonstrate the dynamic, and reader should recognize that the veracity of the exact timing is purely illustrative and should not considered scientific fact. Irrespective of the exact timing of this processing, if an instructor presents too much information at an individual too quickly, the brain simply can’t keep up and shuts down.  Conversely, if the brain receives information too slowly, the mind tends to wander and seek out other input to process; a phenomenon is commonly called daydreaming.

There are ways with which an instructor can hold people’s attention longer.  First, the instructor should vary the delivery methods.  Many safety instructors have one delivery method: lecture.  Lecture is very useful and widely used in traditional education and it certainly has a place in safety training, but it shouldn’t be the only method an instructor uses. Lectures are popular among safety instructors because people tend to model the methods most familiar to them, and since most safety instructors sat through numerous lectures in college, they gravitate to this delivery method. There is an opportunity here for OSHA to develop guidelines for developing courses that will meet its standards and for shifting its policy away from a more broad-based and flexible approach to its training to a more clear and prescriptive approach.

A ten minute lecture that introduces defines and explains a topic is an excellent way to provide the participants with a lot of information quickly, but then a good instructor should use another delivery method to illustrate the point.   Many instructors like to use question-and-answer (Socratic method) or a group discussion to illustrate the skills they are trying to teach, but others might also consider a case study, a video, or a simulation exercise to illustrate a key point.

Case studies and simulation exercises are best used during the demonstration and practice steps of the instructional process.  A case study is typically an in-depth examination of one specific situation that is representative of the circumstances under which the learners will apply the skill.  A good case study should have a dilemma that the learner is asked to solve.  When one writes a case study, one must ensure one provides enough information so the learners can draw correct conclusions but not so much information that the learners will find the solution to the problem obvious.

Writing a good case study is similar to writing anything worth reading—it must keep the reader interested and engaged—except that case studies differ from written descriptions in that case studies are designed to teach a lesson of some sort.  But a well-written case study is only part of what makes the tool valuable.  In the case of OSHA required safety training, a case study could get at the heart of why the particular training is required to begin with. Facilitating a case study is at least as important as how well the case study is written.  While case studies can be used as part of individual or group work, a highly effective technique involves dividing the class into small groups and having the participants engage in discussion.  When facilitating a case study, the facilitator should have the participants in each group read the case and discuss the questions that are either included in the handouts or posted in the room. (Posting the questions obviates the need to have the facilitator keep repeating the questions to throughout the exercise.) Once each group has discussed the questions and arrived at a consensus the facilitator should ask a group spokesperson to share the group’s responses with the entire class. The discussion of the case study in the entire group will allow the facilitator to gage the learners understanding of the points most germane to the case study.

Evaluating the Effectiveness of Safety Training

When it comes to evaluation there is no substitute for a good experiential exercise (or simulation).  An experiential exercise/simulation is a controlled environment where the learner can perform the skills without exposing themselves to real-life dangers associated with performing the skills under actual working conditions; this is key in safety training.  An excellent example of the effectiveness of simulations is the training conducted in a nuclear power.  One can imagine how important safety is when working around potentially radioactive materials, and can probably understand how much safety training the average nuclear facility requires its workers to compete.  A course on the proper use of Personal Protective Equipment (PPE) associated with entering a radioactive area would pose a particular problem.  Obviously the instructor can’t take the learners into an actual radioactive area for training because the consequences for incorrect performance would be dire.  The situation is complicated because typically such training is conducted with over 25 participants, and there are seldom more than only two or three sets of PPE available for training. (These suits are expensive and typically only issued to people who will work in an environment requiring them even though training is required for everyone.) Despite these challenges the instructor can train workers in the procedure for putting on the gear and taking it off by using a simple simulation.  The instructor need only designate an area of an adjacent room (using masking tape to mark the boundaries of the area) as “radioactive”, the facilitator then instructs the group to (in pairs) demonstrate the proper procedure for putting on our imaginary gear, and then removing the gear.  The procedure for doing so is painfully specific, with each piece of gear requiring that it donned in a specific order.  If a participant erred while removing the gear the facilitator observes, “congratulations, you are radioactive” and ask offending participant to go to the end of the line.  This, and similar situations can be fun, but more importantly, the learners retain important skills that may one day save their lives.  This fictitious exercise can be more than just engaging; it can be meaningful and effective.

Safety Training Is Indiscriminate 

Far too often a population is provided safety training that it doesn’t need or is provided a level of training that is deeper in scope than would ever be required to protect the worker—even in the most extreme cases. Workers, who might only require a warning, are instead required to complete training that provides higher level skills that they will never use. And because a key requirement of adult learning is relevance, this safety training “over kill” produces a sense of triviality among the learners. Since there is such poor delineation in the OSHA requirements between the needs of a few key positions and the general populace training tends to be aimed at the lowest common denominator, i.e. organizations provide training to too broad an audience rather risk violation of a requirement.

Determining the Appropriate Audience for Training

A key to providing safety training at the right level of detail lies in the use the words “do” and “know”. The difference between “doing” and “knowing” is substantial, profound and lies at the heart of the difficulties associated with poor safety training. In 1956 a committee of educators led by Benjamin Bloom classified the levels of learning arranged in hierarchical order. This work, which came to be known as Bloom’s Taxonomy, identifies the level of skills mastery with which a learner should acquire to achieve the course goals. Bloom, and subsequent researchers identified three domains: cognitive, affective, and psychomotor.  Skills associated with the cognitive domain focus on knowledge, comprehension, and critical thinking. Safety training tends to focus on training on the lowest levels of the cognitive domain, but such focus is inappropriate for protecting workers.

Bloom’s Taxonomy

Bloom et al identified six levels in the taxonomy: knowledge, comprehension, application, analysis, synthesis, and evaluation.  Unfortunately, most safety training stops at the first two levels, and in some cases focus only on the knowledge. Ostensibly, this focus seems to make sense, after all, we can’t expect workers to follow safety rules if they don’t know the rules exist or don’t understand how the rules apply to them.  But there is a chasm between knowing and understanding the rules and following these rules.

Most safety training falls short of addressing skills at the application level and this is a serious shortfall.  Safety training needs to impart skills that can be transferred across varied and diverse.  The workplace is dynamic and hazards can crop up unexpectedly and unpredictably and good safety training should prepare workers to deal with new hazards.

OSHA-required training seldom addresses skills at the analysis level and in so doing, ignores some of the most crucial skills for protecting workers.  Analysis-level training helps the learner to divide content into its basic elements and to organize ideas.  At this level, the prime objective of training is to give the learners skills necessary to problem solve. Because the learner is able to extrapolate new skills from the application of existing skills the learner is better prepared for assessing risk, troubleshooting, diagnosing process flaws and, in general, thinking proactively about ways to make the workplace safer.  The lack of requirements for analysis-level safety training underpins the criticisms leveled at OSHA-required training.  Such criticisms are unfair and misguided; it is not incumbent on OSHA to compel employers to do what companies should intuitively understand as being in their own interests.

The next level of training on Bloom’s taxonomy is Synthesis.  Synthesis-level training builds skills relative to combing varied sources to create a true innovation. While analysis builds skills that help workers to discover hazards and have a deeper understanding of the causes of worker injuries, synthesis-level training help workers to craft new and innovative solutions that can make the entire workplace safer.  Synthesis-level training will tend to blur the lines between traditional safety training and job-specific training. Because this training is more deeply imbedded into the curriculum than the training at lower levels, it is unreasonable to expect OSHA to require training this extensive, but clearly, imbedding synthesis-level skills into all its training.

The highest level of training in Bloom’s Taxonomy is Evaluation.  Safety training designed to impart evaluation-level skills is intended to help worker to make sound judgments relative to the efficacy and value of ideas or materials. Evaluation-level training is paramount to transforming a corporate culture from one where safety is seen as an obligation to one where safety is seen as process improvement.

A Lack Of Relevancy

Adults need to be able to directly relate a topic in a training course to a real-life need. Respected researcher and author on the topic of andragogy, Malcolm Knowles offered some fundamental differences between how adults and how children learn.  According to Knowles, a key means for motivating adults to learn is to demonstrate the relevancy of the topics to a skill that the adult learner perceives as useful.  Safety training often lacks this essential element, and topics seen as irrelevant are not likely to be retained.  While the OSHA requirements encourage employers to provide training that addresses the specific needs it doesn’t mandate that the training be relevant to the job requirements.

Even training that is relevant in the broadest sense—e.g. training in the safe response to a natural disaster—may not seem as important as other training owing to the remote chance that such skills will ever be required. There are two dynamics at play in this scenario: all safety hazards do not carry the same perceived weight, and the commitment to the training by the learner directly correlates to the perceived relevance to the learner’s need.

The argument that safety training does not apply to the hazards generally faced by the adult learners is a fairly specious one.  The problem is typically not in the applicability of content but in the course or course facilitation, but in a flaw in the design where the course fails to connect the topic to a meaningful What’s In It For Me: (WIIFM).  Unless the course facilitator can make a compelling argument for the usefulness of the course content the adult learner is likely to mentally check out and retain little to no course content.

Compliance At The Expense Of Safety Skills

A lot of safety training is seen as a necessary evil by the organization and major inconvenience by the individual.  It is impossible to provide training to people that honestly and ardently believe that they aren’t attending the training, they are being subjected to it. Yet organizations have to do safety training to comply with the law. There isn’t a choice; organizations have to present safety training and people have to attend it.  While compliance is certainly an important part of why organizations do training, it MUST be secondary to protecting workers. There can never be a trade off between imparting skills necessary for workers to be safe and complying with regulations.  An organization should never tell an adult that the reason they are in safety training is because the law says they have to be—that may well be an accurate statement, but it sets a tone where the participants are being treated as convicts or children. The current OSHA structure for the oversight of safety training perpetuates and reinforces “compliance over quality” thinking. Consider, Hazard Communication training;  Haz Com used to be, for many, the symbol of pointless compliance training.  Workers believe that organizations conducted the training annually, not because it was necessary or valuable, but exclusively because the law required it and if the organization failed to comply it risked a big fine. How likely is it that adults will be receptive when they feel that they were dragged into the class against their will?  But if a facilitator were to focus on the skills the organization wanted the participants to learn, instead of the compliance box it was going to check the organization could make some significant and important improvements to the course.

Link Safety Training to the Intent of the Regulation not to Compliance

As organizations seek to improve their safety training, it should begin by asking why OSHA required the course. The identification of what OSHA expects people will do differently after having attended the training will help organizations to retool the course to meet the goal of warning people about dangers in the workplace while informing them of their rights under the law instead of merely checking the compliance box.  This is more than an issue of deepening the learner’s appreciation of the relevancy of a safety course; the failure of the organization to provide safety training that is relevant and that identifies the WIIFM encourages organizations to falsify training records.  Far too many organizations circulate a document and have workers sign a bogus sign-in sheet instead of providing an actual training course.

Policy Implications

OSHA has done an outstanding job in creating a climate where employers understand that they must comply or they will be fined or will face other legal consequences.  While considerable effort is spent ensuring that companies present the required training, little is done in the way of evaluating the quality or effectiveness of this training.

Shift the Focus Away from Compliance

While it is unrealistic to expect that OSHA will begin to evaluate the quality of individual training courses, it can shift away from the binary “complete or incomplete” view of worker safety in favor of an audit system that identifies the vital behaviors and critical indicators that demonstrate a movement toward a culture of safety. The quality of safety training would rapidly increase if OSHA would increase exponentially if it would shift the focus of its compliance audits away from attendance and documentation of training course and toward the analysis of the quality the training delivered. Such an audit process is not impossible, in fact, it is not even unprecedented; currently there is no expectation for OSHA auditors to qualify the efficacy of the training offered or presented, but auditing of this nature is neither unprecedented nor unduly difficult.  The German quality management system, Verband der Automobilindustrie (VDA), has specific requirements that include ways for evaluating the effectiveness of training.

Stewarding OSHA Resources

The policy implications of OSHA audits that measure the efficacy of corporate learning will be significant.  OSHA lacks the resources to field auditors who will routinely judge the quality of safety training.  To obviate this dilemma, OSHA need only shift the burden of proof of quality of safety training from the government to employers.  The International Standards Organization (ISO) and similar organizations have required companies to earn and maintain third party certification for years.  In these scenarios, companies require their suppliers to maintain the certification as a condition of doing business with the companies. The supplier company is required to comply with strict criteria to earn and maintain the certification.  To earn the certification the supplier must first conduct several self-audits followed by a number of third-party audits.  Once the supplier is certified, it must renew its certification at regular intervals.  OSHA would be well served with this model.  In this model, OSHA would need only to require companies of a certain profile to earn and maintain an independent certification.

Better Align OSHA Requirements with Modern Educational Technology

While OSHA encourages employers to evaluate courses and improve them based on input from the learner OSHA stops short of requiring that courses be good, effective, or relevant to the work performed. This not to say that there is no effective safety training but even organizations with the best safety training often are forced to choose between safety training that makes sense and safety training that complies with OSHA requirements.  Consider the requirements associated with eLearning.  Only a handful of eLearning providers are OSHA accepted (OSHA does not endorse these courses and forbids the providers from using words like “approved” or its synonyms) without a proctor.  Imagine the onus this places on Oil & Gas Exploration, construction, or other operations.  This leaves these organizations little in way of options—either they can purchase one of these vendors or they can pay a person to watch another complete an eLearning module, which all eliminates any benefit derived from delivering the training via a distance learning modality.  An audit process that focuses on performance indicators will make it easier and less resource-intensive while encouraging organizations to use safety indicators to drive strategic efficiency goals.  In addition to requiring fewer resources to assess the efficacy of an organization’s safety efforts, this approach lessens the adversarial relationship between OSHA and industry.

Identify Performance Indicators for the Effectiveness Safety Training

OSHA regulations should be modified to include that organizations provide evidence of the identification of performance indicators for safety.  OSHA should be careful not to overstep its boundaries by specifying the precise performance indicators, because differences in industry could make very specific prescriptions inappropriate, but it should provide examples. For example, a prime indicator as to the effectiveness of safety training is whether the course developer followed a basic course design. This indicator can be used to infer better facilitation; Simple Train-the-Trainer workshops based on a simplified (from ADDIE) course development model greatly improve the quality of facilitation by subject matter experts who were pressed into doing training.  OSHA would be well served to evaluate the course design process by comparing it to the following model:

  1. Introduce the topic. Adults need to understand why they should learn the skill, and believe that learning the skill has something meaningful and valuable in it for them.
  2. Define the skill. An effective course design will specifically define the skill and identify the scope i.e. identify exactly what the skill is, and—where appropriate—is not.
  3. Explain the skill. Once a course designer has defined the skill, it requires that the facilitator explain the context in which the person will use the skill, and provide the participants with criteria so they can judge whether or not they are correctly applying the skill.  Far too often skills are defined in such vague terms that the participants what they are expected to learn.
  4. Illustrate the skill.  Using examples, visual aids, or other means, the course should illustrate what the skill looks like when being properly applied.
  5. Demonstrate the skill. Demonstrating a skill is crucial, both in building a skill and maintaining course credibility. Demonstrating a skill allows the participant to see how the skill is correctly performed and can ask questions to clarify things that they may not understand.  
  6. Allow people to practice the skill.  Once people have seen the skill they are ready to try it themselves.  While they practice the skill the instructor should be providing guidance and coaching so that people are able to refine the newly acquired skill in the safety of a supervised situation.
  7. Evaluate the skill.  If the designer wrote a good objective, evaluating the participant’s progress should be very easy; all the auditor need do is to compare the participant’s demonstration of the skill with the criteria for success.

By assessing the evidence presented by an organization that clearly proves that it has followed these seven steps for each of required topics the auditor should be able to be confident that the organization has built the skills that are required under OSHA mandates.

Include Standards for On-the-Job-Training (OJT)

OSHA should broaden its scope beyond traditional safety courses and include standards for On-the-Job-Training (OJT) and other core skills training. This can only be practical if OSHA also implements the third-party audit approach recommended above. The most important Safety training is quality training in the skills required for the worker to do his or her job.  Most workplace injuries are not currently caused because of a lack of safety training rather, a substantial number of injuries are caused by a lack of competency in the worker’s core skills caused a lack of effective training. The use of key indicators associated with quality course development and evaluation of training can greatly improve the quality of the basic job skills training and OJT.

End “One-Size-Fits-All” Safety Training Regulations

Another critical shift that OSHA should make is to move away from the “one-size-fits-all” approach to safety training requirements.  While OSHA does make allowances for very small organizations, it should consider creating more industry specific safety training.

Again, OSHA should shift the onus of the responsibility for defining industry-specific requirements to third-party industry organizations.  Industry organizations are more likely to understand the specific dangers of their industries and can make recommendations to OSHA.  The Unions that represent the workers of these industries should be engaged as key stakeholders before any recommendations are crafted.  The addition of Unions will create added checks and balances to ensure that an industry does not craft recommendations that are too lenient or favorable to an industry while putting workers at risk.

Create Safety Incentives and Rewards

Because the third-party audit process would substantially reduce the demands on OSHA’s  already limited and increasingly taxed resources, OSHA would be better able to offer more rewards for training innovations.  By offering incentives for businesses to proactively attack safety issues, OSHA puts itself in the enviable role of a resource to business instead of a policing agency.

Closing

That most OSHA Safety Training is a waste of time for many organizations is perhaps the worst kept secret in U.S. industry. But effective safety training plays a pivotal role in improving the safety of the workplace and protecting workers.   An effective safety process is built on a foundation of well designed and delivered safety training.  A safer workplace is more than about protecting workers,  creating a workplace that does not injure workers improves productivity, makes organizations more competitive and reduces waste.  It is time for OSHA to a partner with U.S. businesses to enhance and protect our strategic manufacturing base.  The first step to forging this partnership is to dramatically improve the skill-set of the American worker, and to do this OSHA must approach how it audits safety much more differently than it does today.

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