The Right Reason for Respirator Training: If Legal Liability Is at the Heart of Your Respirator Training Program, It Is Destined to Be a Failure
Vaughan, Kenneth, Occupational Hazards
Consider Henry, an operations manager in Philadelphia. For him, the purpose of training is getting workers to fill out the right forms. He has achieved his goal when his filing cabinet is full of certifications, all formatted so the OSHA inspector has easy access to the records of every employee in his company.
Or consider Jane, a risk manager In Portland. For her, training is conducted so she can provide tangible evidence to her legal department. With an Excel spreadsheet at the ready, Jane's task of controlling liability has been accomplished.
Henry and Jane both mean well, but their training programs are failures because they stem from the wrong motivation. In the end, neither manager knows if their employees are adequately trained. Their approaches are a caricature of good safety management.
Forms and spreadsheets are not in themselves proof of effective training, A genuine respiratory protection program depends on proper training, not paper trails. Employees should not be trained to keep OSHA happy. Nor should they be trained with legal liability as a priority. No doubt these are desirable consequences of proper training, but the overriding purpose of responsible training is to ensure the health and safety of workers who wear respirators.
OSHA Standard 1910.134 requires that where respirators are necessary to protect the health of the employee, the employer shall implement a respiratory protection program. This program must include training employees in the proper use of respirators, including instruction for putting them on and removing them, as well as providing information about capabilities and limitations.
Three Phases of Training
For training to be effective, three distinct phases must be completed with the welfare of the worker first and foremost.
Phase One: Focus on the primary purpose of the training.
Best practice ensures the health and safety of workers who wear respirators. Any other benefit obtained is secondary to safety. It is self-serving for businesses to focus on avoiding liability lawsuits, avoiding OSHA fines or trying to keep OSHA at bay.
When workers are safe and healthy, secondary purposes are achieved, but putting secondary purposes first is bad, if not dangerous, practice.
Phase Two: Develop the training framework.
Best practice treats trainees as capable, responsible people, with qualified and committed trainers explaining the use of respiratory protection in real circumstances and offering solutions to potential problems.
Employers should refrain from treating trainees like children and imposing procedures in an arbitrary manner Respirator training is an adult learning activity. Adults learn best when the practical benefits of what they are taught are clearly explained. Site-specific conditions should be demonstrated and specific protection practices reinforced. Employers should develop a training framework to support such instruction.
Part Three: Implement contextualized training.
Best practice makes training relevant and takes into account specific work conditions. It is careless to generalize training so that it has no specific meaning or value to the worker.
Timing is critical when it comes to training. A conscientious employer should complete respirator training before the worker uses the device on the job. Respirator training should not take place on the job, where it's likely to compete with other responsibilities for the worker's attention.
Workers must be fully aware of the risks they face in their workplace, and understand that respirators are provided for their safety. When workplace hazards are divulged and relevant facts disclosed, employees become participants in their own safety program.
Employers should explain the capabilities and limitations of respirators. It is negligent for employers to select a specific type of respirator and impose it use without explaining why it is the right product for a specific environment Users must be able to relate the performance of the respirator to the hazards that they face in their own circumstances. …