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Issue:
As a responsible employer, you are providing
safety training to your construction employees. But can employers rely
solely upon training videos to comply with OSHA's employee training
requirements for construction under section 1926.21(b)(2)?
Answer:
Probably not . . . OSHA has cautioned
against the exclusive use of videotape training in construction. The
construction standard that addresses training requirements states: "The
employer shall instruct each employee in the recognition and avoidance
of unsafe conditions and the regulations applicable to his work
environment to control or eliminate any hazards or other exposure to
illness or injury." OSHA has interpreted this to mean that training must
be tailored to the employees' language and level of education, the
hazards its employees will encounter, and that the employer must convey
the required information to its employees. OSHA summarized its position
on the standard by saying that an employer is required to provide
effective training. Confusing? You bet!
So what constitutes effective training and what is a responsible
employer to do? The employer should do everything within its power to
provide proper safety training for its employees. This is usually best
accomplished through:
- Providing employees with safety information;
- Enrolling employees in safety classes;
- Offering training that is interactive and hands-on; and
- Following up by testing employees to ascertain if the employees
have understood what they have been taught.
While all of these steps are not required by the construction
training standard, this would constitute an effective training program.
Providing employees with a training video may be effective for certain
construction tasks, but a comprehensive program leaves no room for
error. |