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When is EHS Online Training Not Enough? A Conversation with Bruce Groves, CIH and former OSHA Officer

Proponents of online training argue that it is cheaper and easier to implement in a world of busy schedules than classroom training. Why WOULDN’T you opt for online safety training?

Many people feel safety is nothing more than common sense. My experience has been that it is much more than common sense. You really have to learn how to identify hazards and how to protect yourself.

Safety training requires individual engagement, and it is most successful when there is good group interaction. For example, effective safety programs are a series of problem-solving scenarios. When you have a group of employees trained as a group, this gives everyone an opportunity to interact and solve problems not as a class full of individuals but as a team. Safety often requires a group of people to figure out how to respond to an emergency where you have to not only solve the emergency you are facing, but you have to make sure everyone is protected during the process. There is no cookie-cutter approach. You are essentially helping people practice good communication and teamwork in addition to using their experience and training in order to have the best outcomes.

For example, something as small as a fuel spill could create a hazard for fire in an environment, as well as a toxicity issue. To understand how to control the spill and reduce the hazards, someone has to exercise good judgment and decision-making quickly. Having rehearsed this in a group setting is preferable to individual learning.

What about online training over some of the newer platforms like Zoom where there can be interaction rather than just playing a video?

I think this type of online training can work in certain circumstances. Especially as we have seen technology like Zoom and Webinars being adopted by employers, instructor-led training over an interactive platform can be very effective. However, you do want to make sure your trainer places a limit on the amount of attendees so that the instructor can go through the curriculum, have sufficient Q&A, facilitate discussions and even breakout rooms, and especially lead problem-solving scenarios.

What I do not think is sufficient is the pre-recorded online training, or what is often referred to as “asynchronous” or on-demand training.

If online training isn’t sufficient, why hasn’t OSHA disallowed it?

There is a conflict between OSHA requirements that call for a set amount of time for training, whether it is online or classroom. OSHA requires many classes like the 40-hour training, the 30-hour training, and the 8-hour refresher. It was originally designed for a training course that had a maximum amount of hands-on demonstration, group exercise, problem solving… which was regularly scheduled into classroom training. These requirements weren’t necessarily developed with the technology options in mind that exist today.

Unfortunately, the push to substitute online training for classroom training still requires the person to sit in front of a computer for a specified amount of time. Even if you can complete a module in seven minutes, you still have to sit and wait until the next module starts. This is not only less engaging but also misses out on the opportunity for group discussion and scenario practice.

Are there any types of training where you would consider online training effective?

Certain administrative aspects of safety, such as hazard communications, can be taught effectively online. We have also seen where blended training works well. Here the classroom portion of many training courses like forklift training, electrical safety, and fire protection can be taught online as long as they are supplemented by hands-on, face-to-face training in order to determine competence.

Blended training works with online training. Unfortunately, many people just use online training without any sort of practical aspect, which is where safety training falls short.

What happens if an employer does not provide sufficient health and safety training?

OSHA clearly requires training at many levels. It is the employer’s responsibility to determine what training is required for each employee depending on their job responsibilities. They also must determine the competence expected from that training. Most importantly, the employer must determine the employee successfully passed the course and shows competence in doing their job.

The lack of training or inadequate training could receive a citation from OSHA. Depending upon the standard, the fines can range from up to $7,000 for serious citations to $70K for willful citations (doublecheck.) Serious citations are violations that could lead to serious injury or death (e.g., electrocution, falling, exposure to toxic chemicals or viruses). A willful violation is typically a serious citation where the employer knew there was a training requirement and wantonly disregarded the step to train their employee.

Have you ever responded to an emergency that was caused because people weren’t trained correctly?

Yes. I was called in to negotiate with OSHA on behalf of a client that was being investigated for a fatality at a job site. Workers at this facility had to clean large diesel fuel tanks. They had to enter these tanks, and they were used to having diesel fuel in these tanks. In this one case, someone had placed chemicals instead of the diesel fuel in the tank. Unfortunately, there were no standard procedures that were followed and employees had not received ample training to prepare them to enter a tank.

A person entered the tank with chemicals and immediately fell to the bottom of the tank and died. The company had not conducted an adequate hazard assessment, nor did the worker have the appropriate PPE. There were no instruments to measure air quality, and there was no way to rescue the guy when he went down.

Ultimately, we developed standards, protocols, and training to rectify this situation, but not before it cost a life. With the appropriate training, the individual might have been spared.

Bruce Groves is the CEO of Emilcott Associates, an environmental health and safety consulting firm with offices throughout the east coast.

Please reach out to info@emilcott.com if you need assistance developing and implementing proper safety training programs.