The Occupational Safety and Health Administration (OSHA) creates and enforces environmental, health and safety (EHS) standards for U.S. workers. Many of these standards come with specific training requirements. From the perspective of a trainer or instructional designer, these requirements can be a godsend or a pain in the neck. On one hand, they spell out what you need to include in your EHS training to comply with federal requirements. On the other hand, once you have created a training course or program around a standard, it can be a hassle to update the content.
This problem is compounded by standards that require annual retraining. Employees who are required to sit through the same training topics each year will naturally develop some fatigue for the subject matter. Many longtime employees reach a point where they could probably teach the topic as well as the trainers, since they are exposed to the hazards the training is designed to protect them from, and they have seen the training so many times. Depending on how many training topics you need to present to your learners, updating your training content every year may not be feasible. In fact, most trainers and training providers do not completely update their training content every year.
How can a you keep training fresh when learners are required by OSHA to retake the training every year? If you take a methodical approach and do your homework, keeping your training up to date can be relatively painless. Here’s how.
Before You Start: Have Federal Standards Changed?
Before you begin to refresh training, you need to know if the standards have changed. For example, when the U.S. adopted the Globally Harmonized System (GHS) in 2012, there was a ripple effect across many different training topics. While the GHS update was somewhat unusual in how many training topics it affected, there can be smaller updates to standards and other laws that may affect your training from year to year.
OSHA standards go through a specific process before they become legally binding, and there are several steps, any of which can take years to complete. Even if you are aware that OSHA is considering an update to a standard that your company needs to comply with, it could be several years until anything definitive happens. It’s easy for these changes to fall off your radar, only to discover that a new standard or a change to a standard has already gone into effect.
Before You Start: Have State Standards Changed?
While OSHA standards apply at the federal level, there are 28 states that have their own workplace EHS programs, which are approved by OSHA but created and maintained by the states to emphasize or strengthen certain areas of workplace health and safety beyond what OSHA requires. For example, Oregon’s EHS department has created its own unique standards on topics, such as labor camps, aerial cableways and tramways, and logging and forestry, which relate to industries and activities that are of particular concern to the Pacific northwest. If you live in a state that has its own health and safety program, you will need to make sure that you’re not missing anything that has changed in the past year.
Before You Start: Has Your Industry Changed?
After educating yourself on current federal and state EHS standards, find out if there have been any new major health and safety trends in your industry. For example, in oil and gas production, it’s common for companies to adopt more stringent requirements than OSHA’s regarding hazards that are common to the industry, such as hydrogen sulfide exposure. In some cases, these voluntary measures can become standard across the industry. These industry-specific best practices may not apply to you, but if they do, they are not created or changed in a vacuum. There will usually be an event that will bring the change to your attention. At the same time, it’s a good idea to survey people in your company or at other companies in your industry to find out if you’re up to speed.
Updating Your Training Content
How you will update your training content depends on the format in which you’re currently delivering your training. For example, if you train in person and rely on slideshows, you have less work to do than someone who uses a video-capture software or e-learning authoring tool. Regardless of what type of training you’re creating, there are three main elements to address.
Pay careful attention to the graphical content of your training. For example, the GHS system changed the placards, labels and signage used for chemical storage and shipping containers and changed material safety data sheets (MSDSs) to safety data sheets (SDSs). Organizations, therefore, had to change all images of labels, placards, signage and MSDSs. Other graphical changes can include the work machines, equipment and work sites portrayed in your training. These changes may not only be required because of OSHA updates but also because of state, local or industry changes.
As with the training’s graphical content, it’s important to identify and replace any on-screen text that communicates out-of-date information. This process often requires a sharp eye. For example, in hazard communication courseware, it was easy for organizations to change all on-screen references to “MSDS” with “SDS” and “Material Safety Data Sheets” to “Safety Data Sheets.” However, there may have been a few places in related courseware, such as compressed gas safety and flammable liquids safety, where organizations might have missed the verbiage.
Organizations that use e-learning or, sometimes, slideshow presentations will need to address audio changes. Depending on how you’re generating your narrative , you could face extra costs if you need to edit it more than once. Even if you record the audio yourself, if you must re-record several times, you could wind up wasting time in front of the microphone.
The world of OSHA regulations can be a bit difficult to get the hang of, but any trainer or instructional designer can generate good, up-to-date training with a little bit of know-how and effort. In the end, the results will be worth it. Creating training that your learners will pay attention to and retain is the end goal, and ensuring that their training is carefully updated and refreshed when necessary will help you meet that goal.