From: "Wright, Mike" <mwright**At_Symbol_Here**USW.ORG>
Subject: Re: [DCHAS-L] EXTERNAL EMAIL: Re: [DCHAS-L] Fwd: OSHA COVID-19 Tip of the Day for October 23, 2020
Date: Sat, 24 Oct 2020 15:43:52 +0000
Reply-To: ACS Division of Chemical Health and Safety <DCHAS-L**At_Symbol_Here**Princeton.EDU>
Message-ID: 2b8e2ff4279640e29608a158ea6297c7**At_Symbol_Here**usw.org
In-Reply-To <577309019.2266662.1603498164794**At_Symbol_Here**mail.yahoo.com>


The problem with OSHA-mandated training isn't documentation, it's quality. Most standards that require training don't directly require documentation; Powered Industrial Trucks is an exception, but even there what gets documented is the certification that the training leads to. Nevertheless, employers almost always "document" the training so they can prove they did it. That's usually done by a sign-in sheet. But that only documents attendance. OSHA will cite if the required training wasn't done, but I've never seen a citation for poor training. In the agency's defense, it would be hard to sustain, given how subjective the judgement would be.

 

Many of our employers do very good training, and they'd do it even if OSHA didn't exist. A lot of it is designed by joint safety committees, and delivered by experienced workers - both in classroom and on-the-job. We've also designed modules on hazard communication, process safety management, accident investigation and what we call "systems of safety," which is an expansion of the hierarchy of controls.

 

Sadly, however, some employers skimp on training. We've seen cases where a 10-minute video gets teed up, during which everybody signs a sheet, and bingoÑthey're all trained. We once ran a little contest to find the shortest employer hazard communication training. The winner came in at a little over three minutes.

 

We're also seeing a lot of OJT training being done by inexperienced workers, either because there's high turnover or because management doesn't want to assign the more experienced and productive older workers. We call it "green training green," and it's a real problem.  

 

The Hazwoper standard at least requires minimum training hours, but it's an exception. MSHA is a lot better. New miners get a week of classroom training (except in surface stone, sand and gravel operations), and then an 8-hour refresher every year. That doesn't guarantee quality, but it helps.

 

One last point: we use the word "training" a lot, but we really prefer "education." They may be synonyms, but to us, training deals with how to do a job. Education is a more thorough grounding in why it's done that way and how that job fits into the more general process. We've had fatalities where people followed the job steps precisely, but circumstances had changed in a way they didn't fully understand.  

 

Mike

 

 

Michael J. Wright

Director of Health, Safety and Environment

United Steelworkers

 

412-562-2580 office

412-370-0105 cell

 

"My friends, love is better than anger. Hope is better than fear. Optimism is better than despair. So let us be loving, hopeful and optimistic. And we'll change the world."

                                                                                                                                                                                         Jack Layton

 

 

 

 

From: ACS Division of Chemical Health and Safety [mailto:DCHAS-L**At_Symbol_Here**Princeton.EDU] On Behalf Of Monona Rossol
Sent: Friday, October 23, 2020 8:09 PM
To: DCHAS-L**At_Symbol_Here**Princeton.EDU
Subject: EXTERNAL EMAIL: Re: [DCHAS-L] Fwd: OSHA COVID-19 Tip of the Day for October 23, 2020

 

There are many laws like Hazcom that require documented training.  I have a list somewhere of about 15 such laws. Monona

-----Original Message-----
From: Daniel Kuespert <0000057d3b6cd9b7-dmarc-request**At_Symbol_Here**LISTS.PRINCETON.EDU>
To: DCHAS-L**At_Symbol_Here**Princeton.EDU
Sent: Fri, Oct 23, 2020 4:12 pm
Subject: Re: [DCHAS-L] Fwd: OSHA COVID-19 Tip of the Day for October 23, 2020

No, they cannot. As I recall, there was a court decision (OSHA v. Westvaco?) that held that OSHA cannot require any documentation not specifically asked for by a reg. The decision had to do with the Process Safety Management standard, which has specific documentation requirements, and OSHA tried to cite Westvaco for not having some docs that they weren't required by reg to have. Annoyingly, I cannot find the reference, though. Might have been OSHRC, rather than a court, but I can't find it there either.

 

Figure on it this way: if it hasn't been through public review and comment (via the Administrative Procedures Act processes), then they'd be free to require different docs of different companies, which is kind of the definition of "arbitrary and capricious."

 

Regards, Dan

Sent from my iPad



On Oct 23, 2020, at 15:17, DCHAS Membership Chair <membership**At_Symbol_Here**dchas.org> wrote:

?

I found today's Covid tip from OSHA odd. It's a "good idea" to document safety training? OSHA doesn't require this documentation?

 

- Ralph



Begin forwarded message:

 

From: "OSHA Tip of the Week" <osha.news**At_Symbol_Here**subscriptions.dol.gov>

Subject: OSHA COVID-19 Tip of the Day for October 23, 2020

Date: October 23, 2020 at 9:11:04 AM GMT-4

 

 


 

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Ralph Stuart, CIH, CCHO
Membership Chair
American Chemical Society Division of Chemical Health and Safety


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