CHAPTER 6 - TRAINING

 

A. INTRODUCTION

1. Safety information and training must be effectively and frequently communicated to staff to ensure that a safe operating environment becomes a regular and essential part of conducting business. The SI objective is to create and sustain positive cultural and behavioral changes in using safe work practices for the employees' personal safety and that of their coworkers. This is a key element of the SI goal of zero occupational injuries and illnesses.

2. Safety training requirements are comprehensive. Senior management needs to set the culture and climate on ways and means to lead and support their safety program. Staff and supervisors need training on the hazard controls and environmental compliance requirements specific to their job tasks and those under their purview. Safety Coordinators and safety committee members need additional skills in program management and self-assessments.

 

B. CHAPTER-SPECIFIC ROLES AND RESPONSIBILITIES

1. Directors shall:

a. Ensure sufficient training for Safety Coordinators and safety committee members to allow them to perform their assigned duties and to fulfill their training plan requirements of this Chapter.

b. Ensure sufficient funding and opportunity for all staff under their purview to receive the safety training required by this Manual.

c. Ensure safety training is performed as required by this Manual.

2. Safety Coordinators shall:

a. Identify, with the assistance of supervisors and the Office of Safety, Health and Environmental Management (OSHEM), employees requiring safety training per the requirements of this Manual, and develop a training matrix (see Attachment 1 for example) to ensure that this training (and any periodic refresher training) is provided according to the deadlines established.

b. Develop employee safety training programs to fulfill requirements of this Manual.

c. Assess the effectiveness of the training received, as demonstrated by the proficiencies of the trained employees, during facility safety assessments.

d. Maintain an auditable system of employee training records, for the purpose of ensuring that all staff who require training have received it and are up-to-date with periodic training.

3. Supervisors shall:

a. Assist the Safety Coordinator in developing a departmental training matrix that includes any safety training required by this Manual, so that they are able to identify the employees requiring applicable training, and can properly evaluate the effectiveness of their training programs.

b. Ensure that employees under their purview receive safety training identified in the training matrix developed above and within the established timeframes, including job specific safety orientation and job specific training.

c. Provide ample opportunity for employee involvement in safety program activities within the SI, seek employee input as to the types of additional safety training they would benefit from receiving, and show good faith effort to obtain requested training for them.

d. Maintain documentation of training provided to employees under their purview, as required by this Manual.

4. Employees and others covered by the scope section of Chapter 1, "Overview", of this Manualshall attend required safety training programs and apply the lessons-learned and safe work practices relevant to their assigned job tasks.

5. Office of Safety, Health and Environmental Management (OSHEM) shall:

a. Develop SI safety training policies as required by this Manual, and special emphasis programs as necessary to meet the needs of emerging health and safety topics.

b. When requested, assists Collateral Duty Safety Coordinators in the development of their facility training programs, and coordinates the training needs of the SI.

c. Assess organizational training program effectiveness during the annual Management Evaluation and Technical Reviews (METRs).

 

C. IDENTIFICATION OF EMPLOYEES REQUIRING SAFETY TRAINING

1. Supervisors are to identify the employees who require training in their departmental training matrix and give to the Safety Coordinator for overall coordination. General requirements are included in section D of this Chapter and topic-specific requirements are detailed in the Operational Topic chapters of this Manual or in Attachment 2, SI Safety, Environmental and Health Training Requirements.

a. Individuals will be provided training commensurate with their safety responsibilities in the organization (e.g., senior management, new employees, supervisors, safety committee members).

b. Individuals will be provided training based on their job assignments and results of hazard assessments (such as the Job Hazard Analysis process described in Chapter 4, "Safety Risk Management Program", of this Manual) which will identify safety training requirements.

2. Results of injuries, illness and incident investigations are to be reviewed, by the supervisor and Safety Coordinator with any necessary assistance from OSHEM, to determine specific and appropriate safety training to prevent recurrence of harmful events.

 

D. TRAINING REQUIREMENTS

1. Training for Senior Management Staff.

a. Senior managers (Director and Associate Director level positions) will attend, within 90 days of appointment, with a refresher every 5 years, a Safety Management Seminar, provided by OSHEM through OHR.

b. This seminar will detail senior management roles and responsibilities in developing and implementing the elements of a comprehensive safety program within their organization (per Chapters 2, "Roles and Responsibilities" and 3, "Elements of a Comprehensive Safety, Health and Environmental Management Program" , of this Manual).

c. Senior managers should also attend new employee safety orientation, supervisors' safety training, and any other facility-specific training deemed necessary for them by their Safety Coordinator.

2. Training for Supervisors. Within 90 days of appointment, with a refresher every 5 years, supervisors will successfully complete "Supervisor Safety Training", provided by their Safety Coordinator. Occupational safety and health training for supervisors shall include, at a minimum, information addressed in OSHEM's Training Lesson Plans.

3. New Employee Safety Orientation.

a. Safety orientation will be provided to all new employees, defined as all individuals covered by section B.4 in this chapter who are:

(1) New to the SI,

(2) Returning to the SI after a break in service, and

(3) Those who have been transferred to a different building within the SI.

b. New employee safety orientation will be presented in 3 phases (3.c, 3.d and 3.e below), the first on the day of hire, the second within 5 days of assignment and the third within 30 days.

c. Initial SI Safety Orientation to be conveyed during the Office of Human Resources (OHR) New Employee Orientation on the day of hire.

d. Job Specific Safety Orientation to be conveyed by the supervisor within 5 days of assignment. At a minimum, this information will include:

(1) Safety and security points of contact in the facility.

(2) Fire, medical and other emergency response procedures, nearest exits, and assembly points.

(3) Procedures for reporting hazards, accidents, injuries, and illnesses.

(4) Responsibilities under OSHA to follow SI safety regulations.

(5) Hazards encountered in materials or equipment used in the performance of their duties.

(6) For SI locations with limited access to emergency assistance (e.g., FLWO, Hilo, STRI, Belize) the information needs to also include any specific emergency response procedures pertinent to that locale (e.g., medical response/evacuation, wildfire response, boating safety).

e. Site Safety Orientation to be conveyed by the Safety Coordinator within 30 days of assignment to the facility; it should be a thorough safety orientation that reviews the management, programs, and requirements of their assigned facility. At a minimum, this training shall include information addressed in OSHEM's Training Lesson Plans.

f. Short-term authorized visitors will receive basic safety information pertinent to the location and purpose of their work, prior to or on the day of the start of their business with the SI. As a practical matter, the degree of detail will depend on the level of direct supervision exercised by the SI staff sponsoring their visit, or the provisions of their contract. At a minimum, this information will include:

(1) Fire, medical and other emergency response procedures, nearest exits, and assembly points.

(2) Immediate hazards encountered in the materials or equipment accessed by the visitor or contractor.

(3) Reporting procedures for hazardous work situations, accidents or other hazard incidents.

4. Job-Specific Training

a. Job-specific training based on the training matrix and this Manual will be provided by the supervisor, with assistance from the Safety Coordinator to all persons prior to actually doing work with identified hazards.

b. Retraining, or refresher training, will occur when:

(1) Required by SI policy, required by regulation and/or detailed in specific operational chapters of this Manual and Attachment 2.

(2) A new hazardous process or material is introduced to the job site.

(3) Changes have occurred in applicable safety standards or workplace procedures that render the original training obsolete.

(4) An employee has demonstrated inadequacies in their understanding, knowledge, or skill in the use of equipment, tools, or recognized safe procedures.

(5) An employee has been reassigned to different duties, requiring different safety skills.

5. Construction Safety Training. Construction safety training is required for SI staff (particularly those designated as Contracting Officer's Technical Representatives - COTRs) who are directly responsible for supervision and direction of construction contracts, regardless of their size. This training is also strongly recommended for Exhibit Fabricators, Building Managers, and those staff working in construction-related trades. Training topics will include:

a. Hazard recognition and identification.

b. OSHA Construction Safety Standards.

(Classes taught by SI will also include):

c. Overview of SI construction safety practices.

d. Zero injury techniques.

e. Protection of the public during construction.

f. Staff safety during construction.

6. Safety Awareness Training. Each supervisor will ensure that safety awareness information is provided, or reinforced whenever necessary or appropriate, and on a regular basis, at least monthly.

a. The sessions should be appropriate to the nature of the operation and identified hazards. Examples would range from a monthly newsletter for an office to a review of safety glove selection and care for a laboratory.

b. Employees are to be requested to provide topics for these safety awareness sessions, and provided opportunities to research topics and lead discussions on safety topics they feel are pertinent to their job.

c. The safety discussions are to include (when applicable) a review of the causes and lessons-learned from any accidents or near-misses that have recently occurred within the previous three months.

d. General fire prevention and life safety as it pertains to their work area is to be discussed periodically.

7. Training for Safety Coordinators. Full-time and collateral-duty Safety Coordinators will be expected to fulfill professional development plans described in Attachment 3. OSHEM will provide each coordinator, within 90 days of appointment, an overview of SI safety policy and procedures, and training on this Manual.

8. Training for Safety Committees. Safety Committee training is critical to the effectiveness of the organization's safety program. Safety committee members will receive training from the Safety Coordinator to enable them to fulfill their responsibilities as described in Chapter 2, "Roles and Responsibilities", of this Manual. Training is to be provided prior to the safety committee member's first inspection, as described in Chapter 5, "Safety Assessment, Log of Deficiencies and Corrective Action Plan" , of this Manual. Training topics shall include, as a minimum, information addressed in OSHEM's Training Lesson Plans. Senior Management (Director and Associate Director's) should also attend this training so they understand how their Safety Committee is functioning.

9. Training for Office of Protection Services (OPS) security personnel. OPS security personnel shall be trained by OPS in the detection and reporting of fire hazard conditions in accordance with OPS-31, "Fire Prevention and Awareness".

 

E. VERIFICATION AND EVALUATION

1. Formal hazard-specific training courses required by this Manual will include a means of verifying that the course material was completed. The trainer is to establish the criteria for passing the course (such as written or verbal quizzes, or successful completion of hands-on exercises). The trainer shall also solicit course evaluation feedback from the participants in an effort to improve the quality of the training.

2. Proper application of training concepts learned will be verified by the supervisor through practical observations in the workplace, and by the Safety Coordinator during workplace inspections and program assessments, by observation and interviews, and through analysis of accident and incident reports. Additional training may be recommended by the supervisor and/or Safety Coordinator based on results of this evaluation.

 

F. RECORDKEEPING

1. Documentation of all occupational safety and health training will be maintained by the supervisor and Safety Coordinator and will include: name and signature of participant(s), supervisor name, date, the title and basic objectives of the training program and the name (and signature if feasible) of the trainer. The Safety Coordinator shall verify all training as part of the facility program safety assessment process.

2. Safety, health and environmental training records shall be maintained by the supervisor and/or Safety Coordinator for a minimum of five years unless superseded by a more stringent regulatory requirement. Training retention requirements are detailed in individual operational chapters of this Manual, as well as summarized in Chapter 8, "Program Reporting and Recordkeeping Procedures".