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OSHA Requirements For Training
Have you been putting off your safety training because you just don't know what to
cover? Are you confused about what information to pass on and how in-depth it should be?
You're not alone. Most managers feel the same way. If that's the case, then this article
is good news for you because we're going to tell you exactly what the requirements are.
Although there are over 100 current OSHA Standards that require some sort of training for
the employee, there are only a few topics that apply to the veterinary practice. Many of
those topics, like radiation and anesthesia safety are already discussed on an informal
level at every hospital so you're probably already on the road to success!
Sometimes there is not a specific OSHA standard covering a topic, but since the task has
known hazards, OSHA will use the General Duty Clause in requiring the business to inform
the staff of the hazard. For instance, there is no special standard that regulates
exposure to waste anesthetic gasses, but the Hazard Communication Standard requires that
the practice educate the staff members of the risks and procedures to follow when working
with that hazardous chemical and to take the necessary steps to ensure the workers are not
exposed to the chemical above the permissible level.
To get started on your training program, keep a running list of all the topics you want to
cover. (See the box on page 6 for ideas.) Don't try to cover all the topics at once but
spread them out over several months. Assign different staff members to become the
"in-house expert" on each topic; they will be the person who delivers the
training to the rest of the team.
Although some standards require specific points to be covered (e.g., the personal
protective equipment standard), you would generally be safe to structure the information
so that it covers the following aspects in all training materials:
- information or identification of the hazard or procedure;
- how the hazard affects the worker;
- what the individual worker should do to protect themselves; and
- how to report problems or request additional information, including the location of the
written plan that was developed to deal with that hazard.
Make a training schedule for the next six months or even a year and show when each
topic will be addressed. Even if the practice is inspected before the complete schedule is
covered, the mere presence of a training outline will often impress the inspector enough
that he or she will not issue a citation!
No matter what method of instruction is used, there must be a way for employees to ask
questions or provide feedback. In staff meetings and formal training sessions, that's no
problem, but for individual training times (new employees, etc) the supervisor must make
sure the employee understands the information by having him or her answer questions or
even demonstrating the technique that was just taught. The supervisor or trainer does not
have to be present during the learning phase (e.g., watching the videotape) but they must
follow-up the session with personal involvement.
The main point of every training session must be concern for the worker's safety; avoid
giving the impression that the training is only being done so the business will stay out
of trouble with OSHA. Staff members will relate to the message better and grasp the
information quicker when they feel a personal involvement. If the staff feels the practice
leadership is only doing this training to stay out of trouble with the government, then
they often don't pay attention. If the staff believes this is the practice's attitude
toward safety, they will do just enough to stay out of trouble with you. They'll also push
the limits at every chance to see exactly where you will enforce the rules.
Keep a record of all employee training. It's not enough that you provide the information
and evaluate an employee's competence, you have to be able to prove it. Have an attendance
sheet to pass around for group meetings and make sure everyone signs it. It's also a great
idea to maintain an individual training record for each staff member. Many human resource
professionals suggest keeping the individual sheets in a folder or three ring binder that
is accessible to the employees. The employee and their supervisor are jointly responsible
for keeping the training record current.
Just remember, the bottom line when it comes to safety training is: "the employee
must be competent to perform the task or job in a safe manner."
Secrets to Successful Meetings
One of the most often heard complaints from staff members and supervisors alike is
amount of time that is dedicated to "useless" meetings and training. It seems
the larger the organization grows, the more accurate that complaint becomes. You can avoid
this trap by following a few guidelines for effective meetings and in-service sessions:
- Make sure the topic is relevant and timely. Use a recent situation or medical case to
help illustrate the point of the training. Make the information relevant by using actual
examples whenever possible. Avoid repeating "old news" topics unless there is a
need for new information or remedial instruction.
- Use alternatives to meetings whenever applicable. When you simply have to disseminate
information without evaluating opinion or performance, consider using a memo on the
bulletin board or in each staff member's pay envelope as an alternative to discussing it
in a meeting. This tactic can work both ways. Instead of the traditional "top
down" training, some practices actually require each staff member to submit a
suggestion for improvement or a summation of a journal CE article each month. This form of
self-directed learning is gaining great acceptance in the business world as a supplement
to interactive training topics.
- Not only is this method of instruction more "personal" for each staff member,
the entire organization will spend less time in boring meetings. Of course, not all
training topics are conducive to non- interactive methods, but for those that are, this
method is a great variation on the traditional ways.
- Make sure the audience has had plenty of notice. One of the favorite excuses for missing
training or other important sessions is "Nobody told me!" You can avoid this
annoying excuse by planning the sessions well in advance. Try including a reminder note in
each staff member's pay envelope (or attached to their new time cards) about a week
preceding the event. Also post notices of important meetings on the bulletin board or near
the time clock. Even thought it's not practical to verbally inform each staff member
individually, you can still give them a personal invitation to be present! For dealing
with those staff members who still miss the training, see the article on page 5 entitled
"Make Training Replicable."
- Time the training to the work schedule. Establish a regular time and place for training.
By having the training "built into" the schedule, you have a better chance of
attendance, participation and retention of the materials because the staff does not view
the session as a disruption to the normal work day.
- Ask the staff when it would be best for them. Strive for weekly or at least monthly
sessions that are held on the same day of the week at the same time of the day. Retention
of information and participation increases for meetings in the morning. Thursdays also
seem to be the best days of the week for in-service sessions. Avoid Mondays, Fridays,
lunch-time, late afternoon and after work sessions when enthusiasm is at the lowest.
- Get the orientation training for new staff members out of the way before you become
dependent on their time. Large businesses have learned that if they schedule the new staff
member for orientation on the first two days of employment, it will be accomplished, but
if they wait until the staff member assumes duties, the success rate goes down
dramatically. Use an in-processing checklist to ensure all the little details are covered.
- Dedicate enough time for the topic. Limit sessions to one or two topics and avoid the
tendency to "get it all over with at once." As a general rule, shorter, more
frequent sessions can be accommodated easier than longer ones; most people can find thirty
minutes a week for an in-service session but find it harder to "break-away" for
a full afternoon once a month. It's also been shown that retention of the information and
compliance with the directives is greater when the message is delivered in shorter, more
frequent formats.
- Eliminate foreseeable interruptions. There is no doubt that patient treatments, client
phone calls and special projects are important, but unless they are a true medical
emergency, they should not be allowed to interfere with a scheduled meeting or training
session. Let the senior staff members know that their full participation is expected and
that they must schedule their day accordingly. Don't let one or two
"indispensable" staff members disrupt the session for everyone else.
Most practices will leave a skeleton crew "behind" at the front desk to take
phone calls and assist clients. This may be just one person, but that depends on the
practice. That crew has to watch the videotape of the meeting later; that way everyone
gets the same unfiltered information and the front desk is still covered without someone
running in and out of the meeting.
- Concentrate on the positives. Avoid the urge to use the training for reprimands for past
mistakes. Focus on the correct way to do things and save the reprimands for more
appropriate times.
- Start & stop on time. Be conscious of everyone's schedule; begin and end sessions on
time. Avoid waiting for the chronic "stragglers." By setting the precedent of
sticking to the schedule, staff members will be more interested in the message because
they know this is not going to drag on into the rest of their day. It's better to close
the meeting on time, even if all the information has not been discussed than it is to
extend the meeting. Except in very rare situations, the undiscussed material can be
disseminated by means of a handout or even a memo prepared after the meeting.
By following these simple suggestions, you can hold more informative, less disruptive
meetings or training. Remember that old adage "The team that trains together stays
together!" And who wouldn't want more harmony and less turnover in their staff?
 Check out our
sample training schedules!
More on safety training
Back to OSHA Questions
The information on these pages is excerpted from
The Veterinary Safety & Health Digest,
Copyright 2003 Philip J. Seibert, Jr., CVT All Rights Reserved
No part of this publication may be reproduced for distribution without prior permission
from the publisher. |
