OSHA requires that you provide appropriate LOTO training and instructions to workers depending on their role in and risk during the repair, servicing or maintenance of energized equipment. Click here for a more complete explanation of LOTO training requirements.) Too many employers assume that all they need to do to meet training requirements 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 under the law. Training must be accompanied by follow up and implementation.
Why What Happens After Training Is Just As Important As Training Itself
If, heaven forbid, the worker should be involved in an accident involving the unexpected energization of machinery or equipment being serviced, OSHA inspectors will ask you to provide information documenting the LOTO training the victim received. The inspector will want to know not just what information you provided but why you felt that the message was comprehended.
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. Verifying training involves more than simply making workers sign a piece of paper acknowledging that they understood the lesson. 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.
Also keep in mind that the LOTO standard specifically requires employer to certify that employee training has been accomplished and is being kept up to date. (Click here for a Model Certification form.) Certification must list each employee’s name, and the dates of training.
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, including Fatality Reports and Safety Talks, to deliver effective LOTO training.