Training is a key element of protecting employees from noise hazards. Such training is also specifically required by OSHA if employees are required to use hearing protectors because they’re exposed to dangerous levels of noise exposure, i.e., an 8-hour TWA of 85 decibels or greater.
What Happens After Training Is Just as Important as Actual Training
Training must cover the effects of noise on hearing, the purpose of hearing protectors, the different forms of protection and their respective advantages/disadvantages, as well as instructions on selection, fitting, use and care of various types of hearing protectors.
Too many employers assume that all they need to do to provide training is furnish appropriate training materials to workers. In reality, holding safety meetings, passing out safety manuals and other methods of delivering training is just the beginning, not the end of your training obligations. Training must be accompanied by follow up and implementation.
If heaven forbid, one of your workers should suffer a work-related hearing loss as a result of noise exposure, OSHA inspectors will ask you to provide information documenting the training you provided. The inspector will want to know not just what information you provided but why you felt that the message was comprehended and that workers walked away competent to carry out their responsibilities safely.
Therefore, the first and perhaps most critical phase of follow up and implementation is verifying that workers understood and are prepared to apply what they learned on the job. Simply making workers sign a piece of paper acknowledging that they attended and understood the lesson helps. But it’s not enough. Workers will sign just about anything their employers require them to.
So you need to take additional steps to ensure workers “get it.” Having workers take a quiz after the training session to test their understanding of the key points as recommended above is a good start. Workers who don’t score a certain percentage should get additional training. Repeat the quiz a few weeks or months later to ensure that workers retain what they were taught.
The only sure way to know if training is effective is to observe what the workers do when they get back to the jobsite. If workers aren’t applying their training, you need to intervene and not allow them to do the job wrong. If the problem can’t be corrected on the spot, you’ll need to prevent the worker from carrying out the operation until he receives and comprehends the training necessary to do it safely.
Document Training You Provide
The first thing recordkeeping does to protect you is enable you to gauge the effectiveness of your program. The second thing it does is insulate you from liability by laying down a paper trail proving that you took steps to prevent injuries.
It’s important that you document initial training, as well as annual retraining and any disciplinary actions taken relative to someone not following the safe work procedures. A simple signed acknowledgement that the worker attended a training session is a start. But you need to also maintain training logs.
Government inspectors may not cite you if they observe a worker performing unsafe work practices if you immediately correct the worker, can document he/she had specific safety training at time of hire and/or when they began working in this department, had annual retraining and there is a history of objective and progressive discipline for those who violated your safety rules.
Reinforce Your Message
The final step in training implementation is to continually reinforce the message. At a minimum, follow-up should include efforts to repeat and reinforce the message you delivered.
Hazards that are serious and/or likely to occur might require holding a subsequent meeting of all workers to go over the ground you covered in the first meeting. When dealing with less serious and more remote hazards, it might suffice to post notices in your company’s newsletter or put up some posters on your bulletin board and around the workplace.
We encourage you to use our rich array of training materials for noise protection.[fbcomments]