by Jeanette Showalter
Many Federal/OSHA regulations require specific employee training. Failure to train is one of the easiest violations cited by the responses employees give when asked several specific questions. But who actually needs training? When and how often do they need it? What must they know? When are records necessary?
The following are twelve OSHA training requirements most common to casino operations:
1910.30 Walking/Working Surfaces: Prior to assignment, train employees to: recognize area fall hazards; methods to prevent falls; how to install, inspect, operate, maintain, and disassemble fall protection you provide; and set up and use of dock boards, rope descent systems, and designated areas. Retraining is required when changes are made to the workplace or fall protection; or employee’s knowledge appears inadequate. Training presented must be understandable to all employees.
1910.132 Personal Protective Equipment (PPE): All managers must conduct a survey to determine if PPE is needed, where, and what type. This must be in writing and signed. Train anyone who uses PPE before they are allowed to use it. They must understand what kind of PPE to use (vinyl or rubber gloves for example); how to put it on, take it off, adjust and wear it; what it will not protect them from (N-95 masks do not protect from chemical fumes or vapors); warning symptoms that the PPE is no longer working; and how to clean, care for, store, and dispose of reusable PPE.
1910.134 Respirators: Prior to fit testing, a medical professional must evaluate each employee’s ability to wear a respirator. (Required forms are found in the regulation). Training: Employees must understand why the respirator is necessary; its limitations; what to do in an emergency; how to check and inspect the seals; to maintain and store it; indications that prevent its use (for example: facial hair or difficulty breathing). This training must be repeated annually. Retrain when existing training becomes inadequate or obsolete.
1910.146 Confined Spaces: Prior to confined space work: training in roles and duties; the hazards of the space; protections to be adhered to; equipment set up and use; and emergency procedures. For certification: a written record signed by the employer certifying that the training was conducted, listing training content, employee and trainers names, and dates of training must be available for inspection. Retrain when there are new hazards, different or additional duties, or inadequacies in the employees training. Employees designated to perform rescues from confined spaces have additional specific training requirements.
1910.147 Lockout /Tagout: Prior to assignment, train on the employer’s mandatory written procedures for lock-out/tagout including how to safely apply, use, and remove energy controls; recognize and control hazardous energy sources; understand the employer’s energy control procedures; know the limitations of tags instead of locks; and how to correctly perform the lockout-tagout procedure.
Certification: The lockout-tagout procedure must be observed annually. The employer must sign a written certification listing the persons observed, the equipment locked out, the observer’s name, and the dates. Retrain when job assignments change and when required skills are not retained.
1910.151 Medical Services: Provide first aid supplies and training to ensure that first aid can be immediately rendered, unless a clinic or medical professional is present on site.
1910.156 Fire Brigades: Fire brigades are not required, however employees designated to perform fire brigade duties must be trained annually in their duties. Fire Brigade trainers and leaders must complete more extensive training than the brigade members. If brigades respond to fires inside structures, they must be trained in their duties quarterly. Training must identify special hazards (such as flammable storage areas) and include written procedures for actions to be taken involving these special hazards. (OSHA does not require establishing a fire brigade).
1910.157 Portable Fire Extinguishers: Anyone expected to use a portable fire extinguisher will be trained in their use when first employed, and annually thereafter, in the purpose and use of fire extinguishers of different types, and safe techniques for performing insipient fire fighting. If employees are not trained, the building must be completely evacuated any time the fire alarm sounds.
1910.177 Servicing Rim Wheels: Prior to assignment, train employees on the correct procedure for servicing rim wheels, and the safe operating procedures (found in sections “f” and “g” of this standard). Training will include the content of rim manuals; this standard; the employers (mandatory) written safe operating procedures, and the employer’s enforcement of these procedures.
1910.178 Powered Industrial Trucks: Train prior to assignment by a competent person. Content will include operating instructions, 22 specific items listed in this standard, and five conditions mandating refresher training. A competent person must observe the student operating the truck to re-evaluate proficiency every three years. A signed certification with training and evaluation dates and operator’s names, certifying that training and evaluations were conducted, must be available for inspection.
1910.252-255 Welding and Cutting: Covers oxygen/fuel gas welding, arc welding, and resistance welding. Employees responsible for welding equipment must be judged competent by the employer before being left in charge. Welders and their supervisors must be trained in the proper use of equipment and the employer’s written safe procedures. The person in charge of welding/cutting must designate precautions to be followed before authorizing welding or cutting, preferably by issuing a permit.
1910.332 Electrical Safety Work Practices: Employees will be trained and familiar with safety related work practices required by 1910-332 through 335. This includes how to determine the voltage of exposed live parts and the clearance distances necessary for safety. Individuals that must be trained include: supervisors; electrical and electronic assemblers and technicians; electricians; material handling equipment operators; mechanics; repair persons; painters or welders, “or those they supervise” that work close enough to exposed electrical circuits (50 volts or more) for a hazard to exist.
Learning From the Best
OSHA judges training programs by interviews with employees to see if they know the required information. This is a powerful learning technique, and anyone can use it. Stopping frequently and asking employees to describe what they learned in training has immediate payoffs. Asking about safety outside the classroom tells employees it’s important to know. Training that has been successful shows up immediately in confident responses, while opportunities for training improvement begin to show. The activity motivates employees to pay more attention during actual training so retention improves. And when they have the right answers to your questions, they will have the right answers for OSHA.
Jeanette Showalter is a Health and Safety Advisor with 38 years of experience in safety management. She can be reached by calling (619) 462-4469 or email [email protected].com.