Written by Joey Stokes, Director of Industrial Skills Training for Peak Performance, who is a authorized OSHA Instructor. He is a former maintenance manager and has a master’s in education. Joey is the lead instructor for the Healthy Business Certification that is provided in partnership with state Chamber of Commerce’s and Manufacturing Associations.
If your business is interested in obtaining the Healthy Business Certification, please contact Peak Performance Inc. at www.peakperformanceinc.com or your state association.
Education and Training are
the Key to Reducing OSHA Complaints and Citations
With the ever-changing environment of safety, the two things that remain constant are complaints and citations. Why? Why is this a constant issue? Why do employees complain? Why do employees not use the PPE properly? With the newly released guidance from OSHA concerning Covid-19 and infectious disease, it is a great time to review our policies and procedures.
Employee TOSHA complaints have doubled in the last few months and most of these are PPE or general duty clause. Most could be prevented with education and training. Some of these employee complaints are justified, but many of them are not. Most of these are complaints that the employees do not feel safe or employers are not providing adequate PPE. Employees are often told to wear PPE but are rarely educated on why to wear it. Some employees are given the correct PPE but are not properly trained on how to don and doff the PPE. Proper training, use of, and auditing are all key elements the inspector will look for when investigating complaints. Proper training is a requirement under the OSH act so employees not using the PPE correctly should never happen.
Why are employees so scared? When we are worried, we often revert to the only thing we can relate to. This is often misinformation from movies, social media, or my buddy’s neighbor’s cousin that claims to be a medical professional. For many people, this is the only source of information they have received over the last few months. Getting clear, trustworthy information to our employees that they will believe will reduce complaints.
So how do we educate? Education does not come from a single point lesson and a sign-in sheet. We must have a transfer of knowledge to consider what we do as education. It is easy to sit through a meeting, sign the sheet, and walk away without understanding any of the topics that were covered. A great audit can confirm the transfer of knowledge and protect us against complaints. A non-punitive audit will document that employees follow the policy, identify employees that misunderstood the training, and provide updates to the training to correct any non-conformance with the policy. These audits should not be reserved for once a year nor Friday afternoons.
I attended an arc flash safety awareness training several years ago. The instructor was a district safety manager that rarely used lockout. The presentation was out of date and the instructor was extremely defensive and attempted to avoid all questions about the current NFPA 70e standards. This cast doubt on all training from this person, not just NFPA. When it is obvious the instructor is not and expert on the material, it cast doubts on everything. Educating must come from a trustworthy source.
Small, informal groups is a way to conduct great job specific safety training for employees. The training can be customized for each job and employees are more likely to speak up about any concerns in small groups. We can use this feedback along with proper audits to update our policies. These optimized policies are easier to follow, and people want to follow them because they had input in writing them.
It is easy for us to sit in the office and write policies for our infectious disease programs or any other safety program that follow government guidelines but that does not make it easy to follow them. Spend a day with operations. Spend a day in masks, glasses, and all other PPE required of your employees while doing the same task they do. Do not ask them to do anything they have not watched you do. Build the expectation an audit will occur at any time and these audits are for improvements, not discipline. Create living policies that educate on “why” to remove the concern, the fear, and the complaints.