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Bonus Episode! EHS On Tap E207: Common Misconceptions About Safety Training
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On episode 207 of EHS On Tap, Jill James, Chief Safety Officer at HSI, talks about common misconceptions regarding safety training. This episode is sponsored by HSI.
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Transcript
Introduction to Safety Training Week
00:00:14
Speaker
Welcome to EHS on Tap. I'm your host Jay Kumar, editor-in-chief of EHS Daily Advisor. This week I talked to Jill James, Chief Safety Officer at HSI, about common misconceptions regarding safety training. This episode is sponsored by HSI as part of Safety Training Week. And now, on to the interview. I'm joined today by Jill James, Chief Safety Officer at HSI. Welcome, Jill. Thanks, Jay. It's really good to be back again. Yeah, it's great to have you back. ah For folks who haven't heard you on the show, I was wondering if you could just ah tell me a little bit about yourself and tell me about your podcast too. Sure. So um um my name is Jill. I'm Chief Safety Officer at HSI.
00:00:56
Speaker
and um you'll hear a little bit about some of the things we're doing at HSI I think as we as we talk today. um This is my 30th year in my career of EHS. Started out with OSHA as an investigator and we'll talk a little bit about that today too and what I learned um but i learned from there. um My roles and responsibilities at at HSI um have really been to help our company understand who is an EHS professional. What makes us tick? What are we interested in? What challenges do we face day to day? And then how can HSI as a company help solve for those problems? And yes, you're right. I do host a podcast. It's called the Accidental Safety Pro. We are recording in the month of May 2024, which is also the sixth year anniversary
00:01:53
Speaker
of the podcast that I host, which is an opportunity for EHS professionals to share their journey, share their story ah about how it is they accidentally found this profession, which is a pun for sure. So it's been a great pleasure to capture their stories over all these years. Well, congrats on six years. Um, it's a, it's a great name for podcasts because I was just talking to somebody else yesterday and you know, There aren't too many people who intentionally go into safety as a career.
Misconceptions About Safety Training
00:02:24
Speaker
like They really do accidentally fall into it, so it's kind of perfect, the the name of your show. Yeah, thank you. I appreciate that. It was the first question a marketing director asked me six years ago, well, what are we going to call this? We have to have a name. And I said, I don't know. The first question I always ask when I meet someone new in my field is, how did you find your way here? Because it's always a winding path. Yeah. yeah
00:02:49
Speaker
um so You mentioned obviously that you you worked at OSHA previously and I wanted to get some of your, because we're going to talk about safety training today, but I wanted to get some of your take on common misconceptions and blind spots that safety professionals have about safety training. And I'm sure you've seen plenty of them over the years, you know, in your experiences. Yeah, absolutely. absolutely So as ah as an investigator, part of my job, every single inspection, regardless of the probable cause or reason that I was doing the inspection, was to review and assess the employer's safety training and what they had provided for their employees. And if it if that training aligned um with the type of hazards the employees had exposure to, and of course, what's required under the law. And so I guess
00:03:43
Speaker
You know, one of the unfortunate things that I saw really often was that um some employers believe that showing an employee a written policy and having them sign off and then doing that in air quotes constitutes training. And so the the OSHA regulations for anyone who's ever dug into them um knows that there are many pieces and parts of individual individual laws. So let's take the personal protective equipment standard on the federal level as an example. There's a section of that law that talks about training and that training must be done, and then it outlines what has to be covered in the training. And then there's another portion of that law among other portions as well that says the employer has to have a written assessment.
00:04:39
Speaker
meaning they took the time to figure out what type of personal protective equipment was necessary is necessary for that type of, that place of employment, what you know what sort of hazards there are and what they would assign to employees. and and there And many of the OSHA laws are like that. So there's a training requirement and then some kind of written documentation requirement, whether it's a program or a policy or an SOP or an assessment as ah the case of PPE, um sometimes employers think that OK, if we just have this written document, we have this program and we show it to people, that constitutes training and that's not the case. So that would be a big misconception that I saw pretty often.
HSI's Compliance Assessment Tool
00:05:23
Speaker
um The other one is understanding that when an employer is in a state that is operating under under a state OSHA program, meaning the state has jurisdiction
00:05:38
Speaker
for inspections over those places of employment. Employers don't sometimes understand that they must comply with state OSHA training requirements, if there are any, as well as as well as federal OSHA. And so it's looking at both. So I spend a lot of my time at HSI helping employers understand that. We go to the federal OSHA webpage pretty often. We go to the search bar and we type in state plan state in a map of the United States shows up and it tells you if the state you're operating in has a state OSHA program. And then you can click on your state if that's the case. It'll take you to a summary for your state OSHA program and it'll give you a list of unique standards that are over and above the federal government. And then you can see right right there what the differences are. And then you'd look at that list of topics and dig a little bit further
00:06:34
Speaker
to find out is there a training requirement for that particular topic, or is it more of a performance-based standard? Like, you know, do this, not that, or have something inspected this way, those kind of things. um And sort of in line with sort of our training discussion, you've been doing, you've come up with an interesting tool at HSI that that folks can use to assess their safety training. I was wondering if you could tell us a little bit about it. Right, and so if if anyone has ever dug into the OSHA standards, the OSHA laws, and tried to figure out of and of all of the laws which ones require training, it's a little bit daunting. And and so um over the last number of months, a colleague of mine and I, her name is Kristi, we read every single
00:07:33
Speaker
OSHA Regulation for General Industry 1910, Construction 1926, and the Maritime Laws and the Agriculture Laws. And we searched and sifted by literally going line by line and doing a control search um button and typing in the word train, training, teach, educate, any key words like that and then partnering those with the words shall or should, shall in the words of OSHA means you must do it, should means it's a good idea. And then we um we took what we found, put it on a spreadsheet, captured the regulation, and then we compared it with another document that OSHA has on the federal um website
00:08:25
Speaker
that's um under their section on training. They have a 270 page PDF that's titled training requirements in OSHA standards, where they've pulled out the standards that require training as well, except that document doesn't get updated as often as the actual standards. So we did a side by side comparison there to make sure that we weren't missing anything. And most of the time, a few a few times we found that the PDF was actually missing some things. So that was our those our check-in balance. And then we recorded all of those instances. And then with our webmaster at HSI, we created what we call the OSHA safety training assessment. So we for each of those regulations where it says, must do training, shall do training, we wrote a question ah about that particular standard. And when I say question, I mean, ah someone can pull up to our assessment
00:09:24
Speaker
answer a series of questions that are mapped to that regulation. And the question that's asked is written in such a way that you don't have to be a seasoned EHS professional to know what it means. It means that maybe if you're the HR person, you can you you're going to be able to answer the question. Or maybe if you're just starting out, you'll be able to answer the questions. You'll know what the core of that question is. And then when you work your way through this assessment, the final report comes out that says, okay, you answered yes for these particular topics, meaning you need to provide training for employees on that. It lists the regulation and it also lists the um the recommended frequency of training if that was listed in the OSHA regulations. So we captured that information as well.
00:10:21
Speaker
as long as as well as ah recommendations on which online courses to fulfill those requirements you can take from from HSI. And the great but great piece of it is that, um one, it's free. It's on our website. We really wanted it to be something that enables EHS professionals to assess their work environments. You can take it as many times as you want. there's the the landing page where you're filling out the information about yourself, asks you to list which location you're assessing for. So let's say you're the EHS pro and you're like, I want to assess my location in Michigan at this particular building and structure. You can do that. Then you can take it again for a different location or yeah. Or if you wanted to do it for like a specific department, like just your maintenance department, you could take it,
00:11:17
Speaker
And in your mind's eye, you're holding those employees in your mind and what their exposures are as you're taking it. And then you get an email copy of the report um for yourself every time you take it. And then that becomes your proof, your due diligence. Maybe if you're if you're answering to a leader who says, do we really have to do this? Or how
Addressing Training Gaps and Regulation Changes
00:11:41
Speaker
do you know if we have to do this? Or are you sure we have to do this? You're able to have that document as proof. Yeah, that's excellent. and And you've had a bunch of people ah actually take the assessment and and gotten some feedback, correct? Yeah, we we have. um I've worked specifically with some of our customers who have taken it um since we launched it, and it was just launched weeks ago, who who said you know they're using it as like their gap analysis. like Maybe it's been a while since they've really um thought about
00:12:17
Speaker
you know, maybe some things have changed here. We're we're going to take this assessment. So I've i've talked with customers um who have said, you know, I was missing a few things or I didn't know that, or I worked with ah with a customer of ours a few weeks ago who said I had my um my supervisor at a particular location take it for me. So people are assigning it out as well. And and wow, we we were missing like you know a dozen things or six things here, you know just things they didn't they didn't know about because there are so many regulations and I certainly don't have them all memorized even 30 years into it. and so it's just you know it's ah It's just a nice tool for anyone, whether you're starting out or wonder whether you've been doing this as long as I have and we're pretty proud of the fact that we have this and we're able to offer it um to anyone free on our website.
00:13:13
Speaker
It's right on the land. It's on the landing page. Yeah, it's ah hsi dot.com. It's right there. um Excuse me, so. It's just, you know, obviously it's not like the government's making it, you know, easy to track all this stuff down to you like you know you guys had to. So much work into it. Yeah, just to to put this together. um what What is it kind of? ah Were you surprised at how many people were missing things or was that kind of what you expected to find when you've heard back from folks? ah You know, not surprising, um not surprising, just because there's so many, you know, there's just so many to know. And so, you know, I guess the thing that surprised my colleague Christy and I more was that no one has done this before. um You know, like we we searched, we're like, has anyone ever developed a tool like this before? OSHA doesn't have one.
00:14:07
Speaker
And we you know we weren't able to find anything in the Googleverse, and you know maybe maybe someone's done it, but we haven't been able to find it. And and so this is you know this is great, and we'll keep it up to date as as OSHA changes things. um You and I both know they don't change things very often, but right when when that when Federal OSHA you know finalizes the heat standard, we'll update that. And then we also we also did add in some best practice things as well. um Things that we hear about real often with customers or as an example, um California just recently passed their workplace violence prevention um standard. And so workplace violence is one of the questions on on our assessment. And of course, it's noted that it's not mandatory with federal OSHA yet. um But we we put it in there because it's definitely top of mind for many employers to be doing um training
00:15:04
Speaker
on workplace violence prevention with their employees. So that's an example of something that's in there. Yeah, certainly. You know, even if you're not required, that's a good thing to have as a plan. and You know what to do in those situations. Yeah, absolutely, absolutely for sure. And the you know the other thing Jay that um we get asked really often about, and I've done webinars on this as well, is how often do I have to repeat training just to be compliant? And that's a little bit tricky. because each regulation is written a little bit differently. And so when we when we wrote the assessment, we took note of what each law said, and then we put that in there. So for example, some regulations, not all, some regulations say training has to be repeated annually. One regulation, the forklift operator, says every three years.
00:15:59
Speaker
Um, some it's, it's really ambiguous and doesn't say at all, which means you get to decide as the employer. And then there's all of these, if then statements in the regulations. So sometimes a regulation will say when the responsibilities for the worker change or when there's a new hazard or a risk or some new equipment has been introduced, or maybe there's been a change in the duties for that employee. or we have some kind of proof that the worker's knowledge, you know the training that they had didn't essentially stick. And so you have to retrain um those kinds of things. And that's all captured in the assessment as well.
Institutional Knowledge and Workforce Retention
00:16:40
Speaker
And that's a little bit tricky for people too. Like, oh man, I have to remember that about this particular regulation. Right. Another challenge with training is you know it's there's definitely a struggle to keep ah he
00:16:54
Speaker
workers you know sticking around at your at your company, you know you're either they're leaving the business or retiring, or you know if they're younger, they might just you know stick around for like a year or two and then and then find something else. So you know what do you tell folks win and you know sort of about maintaining that institutional knowledge from folks who've been around for a while and then you know training new folks who may not be there for very long?
00:17:22
Speaker
Right, and so that is that that is the key conundrum. And I think about you know um younger generations of workers have an expectation to have knowledge. you know say Younger generations have had knowledge at their fingertips for their entire lives. And so their expectation is that they are going to get information, they are going to get training, and it's going to be frequent. um and
00:17:52
Speaker
And that's a competitive edge for employers who can do that, to be able to keep things top of mind and fresh and doing things like compliance training, like we're talking about, which is necessary and required, but also the micro-learning things, those things that come day to day to be able to engage and keep keep your workforce so they're not, you know, leaving for somewhere for somewhere else. And then how do you engage your older workforce to be able to, um to work with your not with your younger workers in terms of their institutional knowledge when you have good employees who can really mentor and talk about, you know, um how can you engage with them in terms of how can how can you come alongside your younger workers.
00:18:39
Speaker
um to pass on some of that institutional knowledge. Not the bad stuff, not the, here's the shortcut. yeah but But here, I've done this, this has happened to me, and this is why this is important kind of things. And and I think it's a nice way to bridge um generations of the workplace, being able to find those mentors and mentees. Yeah, I was just gonna say, you know is it just setting up that sort of mentor relationship, yeah you know kind of talking to those older workers and saying, hey, you know yeah We know that you know you you're you know we've got younger folks here and it might be difficult to communicate sometimes, but you know you have all this you know vast information that you've amassed over the last 20, 30 years, and you know we need you to to share that with these folks. so Yeah. but Give it to them a little more, you know ah I guess, weight in terms of you know you've got a lot to offer here, you know please share it. Yeah, particularly with the trades.
00:19:39
Speaker
you know particularly with the trades we do at HSI, a lot of training with the trades as well, um not just health and safety training, but actual you know functional training for their particular disciplines, whether it's you know ah electricians or plumbers or carpenters, whatever the trades are, we we do a lot of training with them as well. And that's exactly what we're finding. These trades workers are critical to our infrastructure, and absolutely institutional knowledge that needs to be passed down and then upskilling that next generation that are going to enable all of us to keep the lights on and the water the water flowing, right?
Modern Training Methods and Technology
00:20:22
Speaker
Yeah, yeah. um you know You mentioned micro learning and sort of new methods of of training, um I guess, the newer generations. Have you seen those being effective you know in the last little while? Are are there things that are that are more effective than others?
00:20:38
Speaker
yeah you know For sure, we certainly see customers who are asking for just-in-time training and um some employers are have asked and do where they're posting like a QR code in a particular area or near a machine for that just-in-time refresher so that someone can use a device, use us as a smartphone or a tablet to bring up that training just-in-time or checklist. you know like Before I do this, here's the checklist I need to go through, and they're bringing it up through a QR code right at the work location. and So it's in their hands immediately, or maybe it's an inspection list um that they're able to use. and So we have we have customers who are doing that as well, keeping things right there and immediately accessible to people. So there aren't any you know excuses or delays yeah um yeah to access to information, which is
00:21:36
Speaker
the you know the powerful things, access. What are the positives and negatives of using AI in in putting together a training? We just recently had a customer advisory board at HSI. We we met just a month ago, um where nearly a ah dozen um EHS professionals from around the world came together to talk with us and one of them talked about AI and how dangerous that piece was in terms of it. It hasn't matured enough to be able to figure out um all of the ins and outs of particular pieces and parts of compliance or hazards or deconstructing things. So for example, as Christy and I were working through just building the OSHA safety training assessment I was talking about, one day we went
00:22:28
Speaker
Huh, maybe we should be asking AI if they can do this for us. So we're typing in all these different, you know, questions to try to get at, you know, what training does OSHA require? And of course it populated a few things, but it was like, you know, a list of 10, not 95, you know? on The other thing, the other thing too is you've really got to review it, right? I mean, cause AI is just learning what's being put into it or what it's finding. So it might if it finds something wrong and mean right and gives that to you as as a solution, you can't just blindly give that to other people. You've got to review it and make sure it's actually you know saying what you want it to say. yeah Yeah, absolutely. I mean, you still need an SME, a subject matter expert, to be able to review um review things. you know I mean, it's kind of the maybe the some
00:23:20
Speaker
In some situations, people have often thought, well, I'll just go to YouTube and I'll search confined space entry training. Well, you you might find something decent on YouTube, but you you might, but you need a subject matter expert. to find like was it? Is this is this right? Did this cover all the elements? I mean, you know that that's that's a completely automate like you know the entire departments. You know you've gotta write somebody reviewing this stuff and and making sure that it's you know it passes muster, right? Right, so I guess we still need humans right now least for now. yeah Yeah, we'll see. We'll see how it goes. el um But I mean, obviously, yeah
00:24:05
Speaker
Do you feel that we're making strides in terms of you know training employees? Do you feel like it's getting better you know just with all these tools and with what we've learned over the years? Certainly. I mean, we we absolutely have more options for training than than we ever have.
Evolution of Training Methods
00:24:23
Speaker
And you know in in my profession, ah many of us you know i acknowledge and kind of laugh about the fact that we're often you know a century or two behind our counterparts in other parts of our organization. you know we We laugh about, oh, we're still using VHS tapes for something. where yeah I mean, some literally are.
00:24:50
Speaker
And then you know you partner that with we're having our employees clock in with optical scanners. you know these two things do These two things do not align. And so that's the big laugh. And and you know with technology, we are certainly blasting our profession right into the current century where we can compete alongside the rest of our counterparts and other parts of an organization and being able to offer training in multiple modalities at multiple frequencies. you know it's not It's not just getting everyone together in a room for a lecture or pressing play on that VHS. It's you know different learning modalities of interactive online training or video training or micro learning or reading articles or following checklists and having it be in people's hands in real time.
00:25:45
Speaker
And you know we haven't had opportunities for that um until sort of recently in our inner profession. Yeah. Well, yeah, it's it's exciting to see you know the new developments. And I'm sure things are only going to get better as ah as we sort of learn
Conclusion and Resources
00:26:02
Speaker
more. So Jill, thank you so much for sharing your knowledge. You're welcome, Jay. Thank you so much for having me. I really appreciate it. Sure thing. and ah The assessment tool you can. If you go to hsi dot.com, it's right there at the top. You can click on take assessment and it'll take hi you right to it and see how you're doing. That's right, thanks Jay. Thank you.
00:26:28
Speaker
That wraps up episode 207 of EHS on Tap. Thanks again to HSI for sponsoring the episode. You can find more information about the show and listen to on demand episodes at ehsdailyadvisor.blr.com. You can subscribe to the show wherever you get podcasts. Thanks for listening and I hope you join me next time.