OSHA reiterates that online safety training may not meet requirements

In a standard interpretation issued earlier this year, OSHA answered the question:

Are online training programs acceptable for compliance with OSHA’s worker training requirements?

Interestingly, this standard interpretation is very similar in wording to one issued 25 years ago. While the agency acknowledges that online training is a useful component of an overall training program, it alone is not compliant. To be compliant, it must have an interactive component: employees must be able to ask questions of, and receive responses from, a qualified trainer in a timely manner. “Training with no interaction, or delayed or limited interaction, between the trainer and trainee may halt or negatively affect a trainee’s ability to understand and/or retain the training material,” according to the document.

OSHA noted that one way for the employer to give workers this opportunity in the context of computer-based training is to provide a telephone “hotline” so that employees will have direct access to a qualified trainer at the time they are taking the online training. But even that is not considered optimum by the agency in regard to certain kinds of training.

“Equally important is the provision of sufficient hands-on training because it allows an employee to interact with equipment and tools in the presence of a qualified trainer, allows the employee to learn or refresh their skills through experience, and allows the trainer to assess whether the trainees have mastered the proper techniques.” Supplementing online training with hands-on training, such as how to use a tool or don PPE, is critical.

The agency also addressed the use of safety training videos and their policy is essentially the same as that for computer-based training. OSHA urges employers not to relying solely on generic, “packaged” training programs in meeting their training requirements as site-specific elements should be included, and to the extent possible the training should be tailored to employees’ assigned duties. They also emphasized that if videos are used, an interactive component must be provided that allows the opportunity for employees to ask questions of the trainer.

It also emphasized that employers must review specific OSHA standards and related guidance to determine what is required in specific situations.

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Ten questions to assess your workplace’s preparedness for an active shooter

While most organizations will never experience an active shooter situation, it’s clear it can happen anywhere and to anyone. According to FBI data, 250 active shootings took place between 2000-2017. From 2000 to 2006, shooting incidents averaged 6.7 a year, jumping to 16.4 a year from 2007 to 2013, and then averaging 22 a year between 2014 and 2017. Nearly half (42 percent) of the incidents between 2000 and 2017 took place at businesses or areas of commerce. In addition, nearly 80% of the 500 workplace homicides in 2016 were caused by shooting, according to the Bureau of Labor and Statistics.

Employers can no longer afford to have a “It will never happen here” or “There’s nothing we can do” mentality. The unpredictability and increase in violence mean employers have to be prepared. Here are ten questions to ask:

  1. Do your hiring practices look for red flags of a person capable of violence or who has a volatile temper? Social media can provide a wealth of information about prospective employees. Hate speech, threats of violence, obsession with guns or violent content, postings of killer’s manifestos, excessive alcohol or drug abuse, undue anger and hostility and so on. Effective screening and background checks are critical even in tight labor markets.
  2. Have employees had recent basic awareness training? The unfortunate reality is that every employee and business owner must be mindful of their surroundings and the potential for an active shooter or other threats. Most shooters are suicidal and their crises are known to others before the attack. Words almost always precede actions and no threat should be passed off as idle words. Involve workers by educating them on warning signs, such as marked change in behavior or appearance, sudden withdrawal, depression or disgruntlement, outbursts of anger, empathy with those committing violence, and so on.
  3. Are employees comfortable reporting their concerns? People who see or sense something is wrong often do not say something. They may fear they are overreacting and unduly labeling a person as a potential threat, worry about confidentiality, or there may be an absence of clear reporting protocols. Employers who respond with punitive actions against the accused foster a climate of silence. However, if these behaviors are recognized, they can often be managed and treated.

    Recently, police say a concerned coworker’s tip may have saved lives after a Long Beach Marriott cook allegedly planned to shoot coworkers and hotel guests. Employees need to understand it’s not about getting a co-worker in trouble, but ensuring the safety of all. It’s about early intervention. And those who are experiencing violence in their personal lives, such as an abusive partner, should be comfortable that sharing the information can be done confidentially.

  4. Are there clear procedures that are followed when an employee is terminated? According to an LA Times article, a change in job status was frequently the trigger for a workplace shooter. They often believe that everyone is against them and termination, no matter how many warnings had been given, is a painful affirmation. Show compassion and offer assistance. While every situation has unique elements, having clearly articulated processes and procedures known by everyone in your organization for terminating an employee is key.
  5. Is there a clear and specific emergency response plan? Best practices change, so there should be a plan to review response plans regularly. The situation is chaotic; the more employees know about how to report and react to an active shooter incident, the better chances of survival. Knowing when to run, hide, or fight and what to do when police arrive is critical.

    There are many resources available, including a Department of Homeland Security’s booklet offering detailed advice.

  6. When was the last time you assessed your physical plant and surroundings for security and tested your security policies and procedures? Having an outside security firm audit can help identify vulnerabilities.
  7. Do you know how your employees feel about workplace safety? A quick survey might provide unexpected insights and lead to important discussions.
  8. Do you have sufficient insurance? In addition to the emotional and psychological impact of such shootings, organizations face sizable property, casualty, business interruption, and workers’ compensation insurance claims, as well as possible litigation. Many businesses think their existing policies cover these events, but they can fall short of covering the huge expenses. Some businesses are supplementing their coverage with active shooter insurance. It’s important to review your coverage with advisors to ensure it is adequate.
  9. Are you prepared to manage the consequences of an active shooter incident? Once injured workers have been taken care of and families notified, attention should be turned to the emotional and psychological state of the survivors. A plan should exist to get them the help they need. Moreover, any critical personnel or operational gaps left in the wake of the shooting should be addressed. Then the situation and response to it should be analyzed and an after-action report prepared.
  10. Are you prepared for the reputation fallout? Reaction will be swift. Your actions will be scrutinized in real time in the media and on social media. Today, there’s no waiting for investigations and so on. How an organization responds can threaten or strengthen its operations.

For Cutting-Edge Strategies on Managing Risks and Slashing Insurance Costs visit www.StopBeingFrustrated.com