OSHA Training is not Construction Training
Since starting CMC Workforce, one of my biggest frustrations has been the misunderstanding about what OSHA Training is and what it is not.
Let’s start with what it is NOT. OSHA Training is not:
Construction Training: It will not teach you the skills needed to build any part of a building.
Pre-Apprenticeship Training: It will not teach you the fundamentals of construction; like Math and Plan Reading.
Apprenticeship Training: It will not teach you the basics of a trade, how to become skilled in that trade and build up the expertise to become a journeyman/woman.
OSHA Training is:
Safety Awareness Training: It will teach you how to be aware of safety hazards and protocol while building a building.
It’s a very small piece of the puzzle, it’s not the whole puzzle. OSHA training is intended to provide basic safety hazard awareness. It is up to the employee and employer to ensure that operations are properly performed.
Is it necessary for Construction Training?
Yes. Absolutely. I stand behind the necessity of OSHA training, but it’s only a small portion of the training that’s needed.
Because of this, it’s embedded, along with SST requirements, into our ICT (Initial Construction Training) Program, along with a host of other certifications, like CPR, Fire Guard, Fire Watch and Anti-Sexual Harassment Training which are woven through our Labor I and Labor II training.
All of our trainees must go through all three training courses before starting their Skilled Trades training in their chosen Trade. This creates a foundation for building a career within a Trade.
Safety is one of the most important things to learn, but it’s the beginning of training, never the end. Giving a certification more weight than it deserves does a disservice to the OSHA program. It also gives the trainees a false sense of accomplishment and entitlement, often making them more reckless in the field.
This is from a letter on OSHA’s website illustrating the difference very well, “.....Occupational Safety and Health Administration's (OSHA) policy concerning the assessment of craft technical skills.
Although several construction standards require employee competency (competent persons or qualified persons), OSHA does not require tests to assess craft technical skills and knowledge. It is the responsibility of the employer to assure that their employees possess the skills and knowledge necessary to perform their tasks safely. When OSHA evaluates the effectiveness of training on a job site, the evaluation will be based on employee interviews and observation of the employees work procedures.”
“Education and training are important tools for informing workers and managers about workplace hazards and controls so they can work more safely and be more productive. Another role of education and training, however, is to provide workers and managers with a greater understanding of the safety and health program itself, so that they can contribute to its development and implementation.
Education and training provides employers, managers, supervisors, and workers with:
Knowledge and skills needed to do their work safely and avoid creating hazards that could place themselves or others at risk.
Awareness and understanding of workplace hazards and how to identify, report, and control them.
Specialized training, when their work involves unique hazards.”
ALL of OSHA’s language speaks to hazard awareness, not competency and craft skills.
On December 29th, 1970 Richard Nixon signed the Occupational Safety and Health Act, the following April the Occupational Safety and Health Administration was established. OSHA ensures safe and healthful working conditions for working men and women by setting and enforcing standards and by providing training, outreach, education and assistance around hazards and safety.
OSHA’s job has always been oversight and centered around safety, not skill building. It is intended to be a baseline around health and safety and not the actual skill training of the workforce.
A fundamental weakness of any standardized training program, like OSHA training, is that the training is rarely comprehensively addressing hazards specific to any one employee role or worksite, this is certainly true in Urban Construction.
To be most effective, safety training must be as relevant as possible to the individual learner and the environment they will be working in. Because of the rigid structure of the OSHA training there is little opportunity to focus on or emphasize specific learning objectives relevant to the learner’s work experience. Thus, even within the small window of Safety Training, OSHA should not be the only training received.
A better approach is base training on individual or common job hazards and establishing links between those identified hazards and appropriate training to address them. These mini lessons are why ToolBox talks were created, but they are often misused. Common on job sites are Safety Stand downs, which is common among strong General Contractors in densely populated areas.
Common construction tasks that could be included in ToolBox Talks are:
Tasks that cause, or may cause, consistent injuries or illness.
Tasks that could cause severe or disabling injuries or illness.
Tasks complex enough that written instructions are needed.
New projects or new to the person tasks.
Projects that have changed recently.
If hazards are identified as significant while conducting a safety analysis, that information can be incorporated into company training. If they are more common and it's simply a matter of awareness building and reminding workers of previous training, ToolBox talks are often useful.
It is important to offer practical guidance and help workers build competency around recognizing, managing and subsequently reporting hazards that they may encounter.
SST Training is not meant to be the only training that employees receive. If your company requires its employees to attend an SST training they certainly will be better equipped to identify workplace hazards, but this only begins to build their knowledge base. It is important that administrators and supervisors convey that the safety training certifications are intended to lay a foundation to build on during future training that is customized to address job-specific hazards and skill building within their craft. Craft skill building training often weaves OSHA language into it as a reinforcement of a common shared language and standard protocol, not the other way around.