Safety training for workers is not just an OSHA requirement, it is the key component to a successful safety program. According to Webster’s dictionary, training is “to coach in a mode of behavior or performance and to make proficient with special instruction and practice.”
Sounds simple enough, but training construction workers is no simple matter. All workers are different, with different experience, different backgrounds, and even different languages, so the safety training needs of each employee must be identified. It does not matter if workers are construction rookies just starting or industry veterans with years of actual construction experience. Employers need to ensure their workforce is trained and qualified to perform the work they are assigned.
OSHA has some very specific training requirements that employers must provide to ensure their employees’ safety. One requirement included in the General Safety and Health Provisions of the OSHA Construction Standards applies to all equipment and machinery not covered by specific standards. The standard 29 CFR 1926.20(b)(4) is often overlooked until somebody is injured or killed and the accident investigated by OSHA. The size and complexity of the equipment or machinery is irrelevant. The standard states that: “The employer shall permit only those employees qualified by training or experience to operate equipment and machinery.”
OSHA expects employers to ensure that each and every employee knows how to safely use the tools, equipment and machinery used to perform a job-related task. This requirement presents what could be a huge undertaking for a contractor. Just think of all the equipment and machinery that can be found in the average contractor’s shop, storage yard, and even jobsite trailer. For example, there are cut-off saws, chainsaws, concrete saws, circular saws, drills, jackhammers, compactors, rollers, ladders, pipe plugs, and many other types of small equipment and machinery. At this point, let’s exempt the large equipment such as backhoes, excavators, bull dozers, front-end loaders and assume that the operators are already qualified by training or experience because most contractors are not going to let just any employee hop in the operator’s seat.
Many of our employees come from the city or from other countries where there is limited if any exposure to power tools and equipment, especially the specialized machinery that we use in the construction industry. It is also important to realize that a large proportion of our workers cannot speak or read English fluently, if at all. This makes the job of managers, supervisors, and safety directors even more difficult because the law specifically states that they must be trained or have adequate experience to qualify them to use the equipment and machinery.
Fortunately, we have access to the internet today, and many companies are providing their managers and foreman tablets and iPads that can be used to obtain training materials while they’re in the field. It is even possible to download a video, instruction manual, or toolbox talk (TBT) to use for training.
Once trained, employees should be able to demonstrate that they know how to safely use equipment or machinery before being permitted to perform any given task. If they cannot, then the supervisor or other qualified person should show and tell them how to use the equipment. Following the demonstration, supervisors should observe the employee until satisfied that the information is understood. It is also a good practice to document the training and instructions for future reference and proof that the training and/or checkout were completed. OSHA and the courts may want to see that documentation during an inspection or if an accident occurs. Remember, if it was not documented, it was not done. Most importantly, training saves lives and prevents injuries: employees are less likely to be injured when they possess the knowledge necessary to safely use tools and equipment or to work in hazardous areas.
It is not necessary for each person to know how to use all of the equipment and machinery on site. Some companies provide individual instruction to employees on an as needed basis, while others take advantage of group training. Toolbox talks are sometimes used to teach and/or remind workers how to use a new piece of equipment or equipment that will be used by workers for a specific job. Hands-on instruction can also be provided in this manner.
The information regarding what each employee must know about any given piece of equipment can be found in the manufacturer’s instruction manual or online by searching for equipment safety manuals. Whenever possible, keep that documentation with the equipment and make copies so even in the event that one is damaged or lost, another will be available. Manufacturers spend a lot of time and money creating the safety information for their equipment to help ensure that individuals are not injured. Many companies also provide free CDs, downloadable videos, and streaming videos that can be used for instructional purposes.
Foremen and supervisors should know how to use equipment properly and share their knowledge with the workforce. Foremen and supervisors represent the company and management; therefore, they should understand that they have a responsibility to observe workers as they perform different tasks and to enforce the safety practices and rules applicable to the equipment and machinery used at their jobsites.
Safety training goes beyond just teaching workers how to use tools and equipment. For example, as I was reviewing the W.H. Feather safety awards applications this year I noticed many of the incidents that occurred were struck-by incidents and strains. Workers were struck by equipment and materials, in addition others strained themselves while lifting or moving materials. Based on the number of lost work days several of these injuries were severe. With that in mind, don’t forget to take the time to teach workers about the other types of hazards that may exist around your jobsites. Some may be obvious and other not so obvious. Start by checking out the new NUCA Struck-by Tool-Box-Talk and other TBTs available to members on the NUCA website.
Training is a never-ending battle because workers come and go, new equipment arrives onsite, materials change, and of course in this business the jobsite changes daily. Ensuring that employees are qualified by training or experience to do their jobs may seem like a tough assignment and it is, but as they say somebody has to do it, and it is the law.
George Kennedy is Vice President of Safety for the National Utility Contractors Association (NUCA) and is a Certified Safety Professional (CSP).