Will your training methods pass an OSHA inspection?
It has always been important for workers to receive safety training in a format they can understand. Now, OSHA is stepping up its checks to ensure this is happening in the workplace.
Secretary of Labor Hilda Solis announced earlier this year that OSHA compliance officers will start verifying not only that required training has been conducted, but that the training was provided in a format that the workers could understand.
Language and vocabulary must be considered
According to an April 28, 2010, policy statement, it is OSHA’s position that, regardless of the precise regulatory language, the terms "train" and "instruct," as well as other synonyms, mean to present information in a manner that employees receiving it are capable of understanding, both in terms of language and vocabulary.
For example, if an employee does not speak or comprehend English, OSHA says instruction must be provided in a language the employee can understand. Similarly, if the employee’s vocabulary is limited, the training must account for that limitation. By the same token, if employees are not literate, telling them to read training materials will not satisfy the employer’s training obligation, OSHA says.
How are other work instructions communicated?
As a general matter, employers are expected to realize that if they customarily need to communicate work instructions or other workplace information to employees at a certain vocabulary level or in a language other than English, they will also need to provide safety and health training to employees in the same manner.
How OSHA will check
OSHA is instructing compliance officers to check ...
- Whether workplace instructions regarding job duties are given in a language other than English and determine whether the employer already is transmitting information with comprehensibility in mind; and
- Whether the training is truly effective, rather than just being completed, i.e., an employer may have training records but employees may not have been able to understand the elements included in the training.
What you can do now
The following are some tips on how to ensure your training is understandable:
- Use a bilingual instructor. This ensures that your non-English speaking employees understand the safety requirements at your company. If that is not practical, a bilingual employee may prove helpful in relaying safety information.
- Offer translated training materials. Give employees training materials that present the information in their native language.
- Keep it simple. If the employee’s vocabulary is limited, you must account for that limitation. Keep training materials simple and avoid technical jargon. Have them translated, as necessary.
- Use visual aids. Signs, pictures, symbols, graphics, posters, and videos are a great way to relay important safety information. Use them during training and as daily reminders throughout your facility.
- Use demonstrations. The best way to ensure employees understand how to do their job is to show them how to do it.
- Offer incentives. Reward bilingual employees who help out with workers who are not fluent in English. Also, consider providing instruction in learning the English language to non-English speaking employees. Over time, this may lessen the need to provide training in other languages.