Describes the employee training content and delivery methods allowed, approved, or recommended in agency rules and policies, especially online or eLearning.
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How to Deliver OSHA, EPA, and DOT--Compliant Training in a Multimedia World
1. How to Deliver OSHA, EPA, and DOT-
Compliant Training in a Multimedia
World
PETE/NESHTA Conference
April 26, 2018
David Galt
Senior Legal Editor—EHS Training
BLR
3. • Information about the audience and their
needs
• Info about hazards/rules/policies
• Delivery methods (class, online, hands-on)
• Content and supporting materials
• Feedback from trainees
• Recordkeeping and documentation
materials
What Do EHS Trainers Need?
4
7. 1. Who needs training
2. Topics/Activities
3. Course content
4. Language
5. Delivery media/method
6. Trainer qualifications
7. Frequency/refresher
8. Recordkeeping
Training Program Elements
9
8. Who Needs Training
OSHA
• Employees exposed
to hazards
– Assess hazards/JHA
(29 CFR 1910.132)
– Identify employees
in jobs/activities
exposed to hazards
• Certified workers,
supervisors, trainers
EPA
• Workers related to
the release of
pollutants, wastes,
etc.
• Workers exposed to
toxic or cancer-
causing substances
• Certified technicians
at testing labs
10
DOT
• Commercial motor
vehicle drivers
• Supervisors for
alcohol and drug
testing
• Employees who
ship, handle, or
transport HAZMAT
9. OSHA bloodborne pathogens
• [E]ach employee with occupational exposure
(1910.1030(b) and 1910.1030(g)(2))
EPA hazardous waste TSDF
• Train facility personnel…relevant to the positions…to
ensure waste mgmt. compliance…respond to
emergencies (40 CFR 264.16, 265.16)
DOT HAZMAT
• Train employees that supervise or prepare hazmat for
shipment…transport (49 CFR 171.8)
Who Needs Training –
Examples
11
10. Who Needs Training –
Contractors and Temps
OSHA
• Host/temp agency
agreements
• Treat temps as own
employees
• Responsibilities
– Temp: general
– Host: site-specific
EPA
• Compliance with regs
when training not
specified
• Prescribed in some
rules (wood
manufacture)
• TSDF contractors are
“ facility personnel ”
12
DOT
• HAZMAT self-
employed person is
“employee” of
transporter, shipper,
offeror
Temp Worker Initiative
11. Covered Topics/Activities
OSHA
• Over 100 topics
• General industry
– topic specific
rule
• Construction –
1926.21 and
topic-specific
rule
EPA
• Air (15+)
• Water
• Waste
• Toxic
substances
• Pesticides
• Storage tanks
13
DOT
• Drug testing
• Driver--safe
operation, HOS,
whistleblower
• HAZMAT
• DOT incident
responders—
HAZWOPER
• LCV (long combo
vehicle)
12. Course Content
OSHA
• Baseline
requirements
• Site-specific
• Detailed for cert
(asbestos, lead,
HAZWOPER)
• Recognized third
party (Red
Cross first aid)
EPA
• Baseline by job
title or activity
• Detailed for cert
• Third party (ABC
wastewater)
• Accredits/
approves certain
vendor courses
• States
14
DOT
• HAZMAT –
5 baseline
requirements
‒ General
Functional
Safety
Security
Modal (air,
rail,
vessel)
13. Language
OSHA
• Not always
specified
• Language workers
understand
(bloodborne,
hazcom, slips/falls)
• Same language as
work instructions
EPA
• Not specified
• Ag pesticides—
in manner that
workers can
understand
(translator)
15
DOT
• Not specified
14. Delivery Methods
OSHA
• Any that meet
objectives
• Some clarify
(HAZWOPER,
bloodborne,
electrical)
• Hands-on
component
EPA
• Not specified
• Lead
abatement—
E-Learning
approved
• States specify
16
DOT
• Any that meet
objectives
• Onsite
exercises
15. OSHA-Required Training Elements
for Overall Program
OSHA rules, LOIs, directives related to
online/computer based training:
1. Two-way communication
2. Hands-on practice
3. Site-specific information
4. Trainer verify competence
5. Qualified trainer
16. 5 Training Elements
1. Two-way communication
• Trainee must be able to ask
questions of qualified trainer and
get answers during the session
• Remote access acceptable
• OSHA rules: bloodborne
pathogens, electrical, silica,
HAZWOPER refresher
• Options
• Phone, email, teleconference
(Skype), live chat, face-to-face
17. 5 Training Elements (cont.)
2. Hands-on practice
• Practice physical skills learned in
the course
• OSHA rules: PPE, fire extinguisher,
respiratory protection, first aid,
lockout/tagout, confined spaces,
HAZWOPER
Options
• Conduct hands-on practice after
online course
• Hands-on practice during pauses in
online course
18. 5 Training Elements (cont.)
3. Site-specific information
• Tailor to specific hazards and
conditions of worker’s assigned
duties
• OSHA rules: HAZWOPER, hazard
communication, LOTO, confined
spaces, electrical, emergency
action
Options
• Customize online course
• Supplement with classroom or
onsite information, exercises,
meetings, talks
19. 5 Training Elements (cont.)
4. Verify competent performance
• Trainer verifies trainee’s competence
to perform tasks learned in the
course—NOT with a quiz
• OSHA rules: Forklifts, PPE,
respiratory, slips and falls, confined
spaces, lockout/tagout, electrical
safety, hazard communication, lead,
asbestos, all construction rules
Options
• “Qualified” trainer / onsite subject
matter expert
20. 5. Trainer qualifications
• Knowledgeable about subject
matter and site-specific hazards
and controls
• OSHA rules: asbestos, bloodborne,
forklift, HAZWOPER, lead, powered
platform, slips/falls NEW, many
construction (competent person)
• Options
– Certification, degree, training,
experience, demonstrated skill
5 Training Elements (cont.)
22
21. • Walking-Working Surfaces (Slips and Falls)
– Qualified: degree, certification, training, experience
• HAZWOPER
– Credentials, or instructional skills and knowledge
– Trained, experienced supervisor for in-the-field
• Bloodborne
– Knowledgeable in subject matter …for workplace
• Forklifts
– Knowledge, training, and experience
– Practical skills and judgment under conditions at work
OSHA Trainer Qualifications –
Examples
23
22. HAZWOPER
• Electronic alone not enough to 100% comply
– Acceptable as part of overall training—if direct access to trainer
Bloodborne Pathogens
• Direct access to qualified trainer during training session
• Trainer can be remote—phone and interactive video
Electrical Safety-Related Work Practices (1910.332)
• Classroom or on-the-job
• Synchronous online meeting w/ trainer remote meets requirement—
if employee demonstrates knowledge and skills locally
OSHA 5 Elements - Examples
24
23. Lead abatement
• e-learning OK for accredited
providers
Hazardous waste generator
• Classroom, hands-on, or
computer-based 40 CFR 267.17(a)(7)
UST A/B/C operator
• State specific
• Online, classroom, hands-on
combos OK (TX, CT)
Deliver Methods – EPA
25
24. HAZMAT
• Train and test by performance, written, verbal, or combo
– DOT has free online modules to fulfill the general awareness
requirements
• Any test method OK – ensure employee performance
Delivery Methods – DOT
26
25. Trainer Qualifications
EPA
• Mostly up to employer
• Site-specific
knowledge
• Asbestos 3,
TSDF/generator, lead
abatement, ag
pesticides, coke oven,
injection wells
DOT
• Mostly up to employer
• HAZMAT determine
on basis of need
• Longer combo vehicle
drivers
27
26. Measure Effectiveness
OSHA
• Inspections,
tests, surveys
• Demonstrate
skill
• Evaluate attitude
toward risk and
hazard control
• Change in work
practices
• Injury rates
EPA
• Rate of release of
pollutants and
wastes
• Compliance with
EPA standards
• Exposure to
substances
(asbestos, lead)
• Evaluations and
exams for cert
28
DOT
• Evaluations
• HAZMAT “
test by
appropriate
means ” to
ensure
performance
• Certificate
27. Refresher Training
OSHA
• Change in job,
conditions,
employee skill/
know-how
• Asbestos,
bloodborne, forklift,
fire extinguisher,
fire brigade,
HAZWOPER,
machine guard,
hearing, PSM,
respiratory,
slips/falls, toxics
EPA
• When out of
compliance
– UST operators
when
noncompliant
• Annual
– Air, TSDFs,
water
• 3 and 5 year
– Air, lead, pest.
29
DOT
• Mostly up to
employer
• 3 years for all
HAZMAT
28. Recordkeeping
OSHA
• Not uniformly
required
• Trainee name,
topic, date
trained, trainer
name
• Certification
(HAZWOPER,
LOTO, forklift,
powered
platforms)
EPA
• Not uniformly
required
• Trainee name,
topic, date
trained, trainer
name
• Certificate
30
DOT
• HAZMAT –
employee name,
date trained,
location of
training
materials, certify
trained and
tested
29. Guidance
OSHA
• ANSI/ASSE Criteria
for Accepted
Practices in Safety,
Health, and
Environmental
Training, Z490.1
E
31
DOT
• DOT Drug & Alcohol
Supervisor Training
Guidance
• HAZMAT—“Guide
to Developing a
HazMat Training
Program” 2009
30. • Online live and self-paced effective case by case and as
part of multimedia approach
– Include trainee communication and feedback
component
• Include hands-on and site-specific component
• Evaluate
– Ensure method available for learners and teachers
• Always document
Points to Remember
32
Notas del editor
Slide Show Notes
Good afternoon, and welcome to this presentation…
OSHA -- Occupational Exposure means reasonably anticipated skin, eye…contact with blood…that may result from the performance of an employee's duties (1910.1030(b) definitions)
OSHA https://www.osha.gov/temp_workers/
https://www.osha.gov/Publications/OSHA3859.pdf
TSDF contractors working at a TSDF are held to the same standards as non-contract facility
Personnel at:
https://yosemite.epa.gov/osw/rcra.nsf/0c994248c239947e85256d090071175f/e710dcf09e849c33852568e3004681b3!OpenDocument
HAZMAT self-employed person http://www.phmsa.dot.gov/portal/site/PHMSA/menuitem.6f23687cf7b00b0f22e4c6962d9c8789/?vgnextoid=cee96bdd00363110VgnVCM1000009ed07898RCRD&vgnextfmt=default
EPA approved accredited training provider e-learning courses for renovation, repair, and painting rule at:
https://www.epa.gov/lead/training-courses#4
The US Department of Transportation does not designate sources of training nor certify training courses, instructors and/or schools. It is the hazmat employer's responsibility to determine the adequacy of the training being presented. Training may be in any appropriate format including lecture, conference, self paced instruction, interactive video, etc.
https://www.fmcsa.dot.gov/regulations/hazardous-materials/how-comply-federal-hazardous-materials-regulations
OSHA - inform and train these workers in a language and vocabulary they can understand.
EPA e-Learning for lead abatement renovator or dust sampling technician training at:
https://www.epa.gov/lead/training-courses#4
HAZWOPER
For uncontrolled hazardous waste site (1910.120(e)(5)): Trainers must have satisfactorily completed a course for teaching required subjects, or
Have the academic credentials and instruction experience necessary to demonstrate a good command of the subject matter and competent instructional skills.
…demonstrate competent instructional skills and knowledge
All days of “actual field experience under the direct supervision of a trained, experienced supervisor.”
Bloodborne
knowledgeable in the subject matter covered by the elements contained in the training program.
…professional trainers, may conduct the training provided they are knowledgeable in the subject matter covered by the elements contained in the training program as it relates to the workplace.(CPL 02-02-069)
National Environmental Trainers, Inc. simulator OSHA interpretation letter at:
http://osha.gov/pls/oshaweb/owadisp.show_document?p_table=INTERPRETATIONS&p_id=27418
HAWOPER 8-hour refresher OK online if:
First, assess employee’s skill level
Direct access to qualified trainer for questions
Audit of hands-on performance of work tasks
Bloodborne
CT approves online training by vendors for A/B/C at http://www.ct.gov/deep/cwp/view.asp?a=2692&q=505750
TX also approves at http://www.tceq.state.tx.us/remediation/pst_rp/ust_training
For longer combo--
Classroom instructors must have audited the driver training class that he or she intends to instruct and, if employed by a training institution, meet all state requirements for a vocational instructor, or meet the substitute requirements
Skills instructors must provide evidence of successful completion of the Driver-Training Program requirements, meet all state requirements for a vocational instructor if employed by a training institution, more….
DOT drug and alcohol training for supervisors at https://www.fmcsa.dot.gov/us-department-transportation-dot-drug-alcohol-supervisor-training-guidance