it, and sometimes they need help spending it. Goal Two: Ensure Compliance Are you audit-ready? Another way that training programs become the organizational Achilles heel is when the metrics look good, but the program can’t pass an audit. Companies that stay out of trouble with OSHA and companies without fear of client-driven safety standdowns don’t usually bear the burden of the dreaded training data call. For unprepared companies that must pull that data, it can be an incredible ad- ministrative nightmare that incentivizes falsifying or gun decking of documents, as managers generate certificates and training rosters aer the fact. But it doesn’t have to be this way. In fact, much of the training documenta- tion requirements that both tradition and best practices dictate are not re- quired by OSHA. For example, OSHA does not require that employees sign or initial training rosters. Here is an OSHA Letter of Interpreta- tion to the National Association of Letter Carriers, which apparently pushed back against a US Post Office mandate that employees sign training rosters. I don’t share this information to dis- courage capturing employee signatures on training rosters. It’s a great practice for many reasons, including employee buy-in and audit trail purposes. And, although not required by OSHA, a cli- ent may require it. However, if your client does not require it and it’s standing in your way of doc- umenting training because it’s hard to get compliance (which in turn is pre- venting documentation at all), then my advice is to stop doing it.
Safely extricating an injured colleague from a tree requires patience, focus, and thorough training.
dard, 29 CFR 1910.132, require verifica- tion, through a written certification, that each affected employee has received and understood the required training. The written certification must contain the name of each employee trained, the date(s) of training, and identify the sub- ject of the certification. It is a common industry practice to take attendance of all employees who attended training sessions; however, OSHA does not re- quire signatures from employees who have attended training sessions.” Methods to Capture Training Here is a partial list of ways to capture training that you may have not considered: • Snap a photo or scan a copy of your old, trusty roster (with or without employee signatures). Don’t let it get lost on the floor of the truck. • Include a block on your JSA or job briefing to capture the training. This way, it will be signed by the crew leader. If the crew also typically signs the JSA, you will get their sig- nature by default. • This method is particularly helpful for “Just in Time Training” (JITT) which can pop up on the job out of necessi-
ty because it addresses an immediate need. For example: you are conducting a JSA or job briefing, and you discover that one or more employees have not received training on a particular piece of gear or equipment. Or you wish to reinforce a particular hazard or control measure relevant to the operation by administering timely targeted training. • Post a picture to the company in- tranet or social feed. This provides a photo with a date and time stamp. Although it may not be enough on its own, it can back up other claims that training did take place. This has the added benefit of helping re- inforce safety and training as part of the company’s culture. • If available, use tools in your compa- ny’s human resources information system (HRIS) or learning man- agement system (LMS). These tools oen provide a way to capture the training while also tying it to an employee’s record and providing a method for tracking recertifications. • Letters on company letterhead are good for qualifications and designa- tions such as a qualified line clear- ance arborist. The letterhead can provide a level of formality (oen
As the Letter of Interpretation states:
“... certain OSHA standards, such as our Personal Protective Equipment stan-
ArborTIMES Summer 2024 | 65
Made with FlippingBook - professional solution for displaying marketing and sales documents online