This last article in our five-part series on auditing your safety and health program according to OSHA's Program Evaluation Profile offers consultant Ray Colvin's thoughts on training, the final PEP component, and on scoring your overall program. Colvin and his wife, Rosemary, are the owners of Safety Training Dynamics in The Woodlands, Texas.

Before you train ...

Before starting a training audit, Colvin suggests reviewing what you've done to prepare for safety and health training. "You should first identify your workplace hazards and write up a hazards analysis, or job safety analysis. This defines how employees will avoid or deal with hazards in your workplace," he says.

These practices - along with any mandatory regulatory training - become your training or learning objectives, which are written into your training plan. Your plan should document the methods used to communicate or teach learning objectives, such as lectures, videos, workshops, hands-on activities, booklets, a combination of approaches, and so on, explains Colvin.

Finally, you need a method for evaluating the effectiveness of your training, such as written tests, skills evaluations, verbal tests, or workshop activity.

In addition to relevant training for employees, OSHA states in its PEP outline that effective and above-average safety programs educate and train supervisors, managers and senior officers about their safety and health roles and responsibilities.

"Ideally, supervisors and managers should be directly involved in employee education and training through their active support and participation in the methods of communication," says Colvin. He adds: "You also have the responsibility to ensure that all employees and contractor's employees are adequately trained to recognize and avoid the hazards of your workplace."

How did you do?

In our September, 1996, issue, we ran a chart showing all the elements of OSHA's Program Evaluation Profile: Management Leadership and Employee Participation; Workplace Analysis; Accident and Record Analysis; Hazard Prevention and Control; Emergency Response; and Safety and Health Training. For each category, points are to be assessed: Outstanding (5), Superior (4), Basic (3), Developmental (2), and Absent or Ineffective (1). The overall score for a work site is the average of the six scores for core elements, rounded to the nearest whole number.

"Your final grade or score on the PEP audit is only secondary to the value achieved by going through the PEP audit process," says Colvin. Here's what he sees as the benefits:

  • Formally "walking" through the internal audit process with managers and employees;
  • Formally reviewing the core elements of a safety and health program;
  • Getting managers involved in the audit process;
  • Making managers, supervisors, and employees aware of the scope and complexity of a formal safety and health program, and of their roles and responsibilities in your program's success.

    Creating a paper trail

    When your audit is completed, share the results with top managers and your legal department. But Colvin emphasizes this key point: "The process of doing an internal audit creates a paper trail of your safety program's weak points. This could be used against your company, and possibly against you, if unsafe conditions are not corrected within a reasonable time and a serious accident occurs."

    To avoid this legal paper trail, Colvin suggests that you first have your corporate legal counsel request the audit. The findings then become "privileged information" that can be withheld from investigators. Many times corporate attorneys hire outside auditors to do the evaluation, says Colvin. This can be done by conducting an internal audit yourself, and then having outside legal sources evaluate your results.

    Don't be gun shy, despite the legal concerns. Remember, says Colvin, "the purpose of an audit is to formally identify weaknesses in the management system that create unsafe work practices and unsafe conditions that can injure workers, diminish their health, interrupt production, or damage products and property."

    Rate your safety and health training

    Safety and health training should cover the safety and health responsibilities of all personnel who work at the site or affect its operations. It is most effective when incorporated into other training about performance requirements and job practices. It should include all subjects and areas necessary to address the hazards at the site. [Guidelines, (b)(4) and (c)(4)]

    1. Facility depends on experience and peer training to meet needs. Managers/supervisors demonstrate little or no involvement in safety and health training responsibilities.

    2. Some orientation training is given to new hires. Some safety training materials (e.g., pamphlets, posters, videotapes) are available or are used periodically at safety meetings, but there is little or no documentation of training or assessment of worker knowledge in this area. Managers generally demonstrate awareness of safety and health responsibilities, but have limited training themselves or involvement in the site's training program.

    3. Training includes OSHA rights and access to information. Training required by applicable standards is provided to all site employees. Supervisors and managers attend training in all subjects provided to employees under their direction. Employees can generally demonstrate the skills/knowledge necessary to perform their jobs safely. Records of training are kept and training is evaluated to ensure that it is effective.

    4. Knowledgeable persons conduct safety and health training that is scheduled, assessed, and documented, and addresses all necessary technical topics. Employees are trained to recognize hazards, violations of OSHA standards, and facility practices. Employees are trained to report violations to management. All site employees - including supervisors and managers - can generally demonstrate preparedness for participation in the overall safety and health program. There are easily retrievable scheduling and recordkeeping systems.

    5. Knowledgeable persons conduct safety and health training that is scheduled, assessed, and documented. Training covers all necessary topics and situations, and includes all persons working at the site (hourly employees, supervisors, managers, contractors, part-time and temporary employees). Employees participate in creating site-specific training methods and materials. Employees are trained to recognize inadequate responses to reported program violations. Retrievable recordkeeping system provides for appropriate retraining, makeup training, and modifications to training as the result of evaluations.