OSHA, Safety Training, and COVID-19

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Two quick notes: Since we originally wrote this article, Vector Solutions (the parent company of Convergence Training) created free online COVID-19 training courses for people to watch. You can view them here.  Also, since we published this article, OSHA has released an update on Safety Training Requirements for COVID-19…please check that link you just passed for our explanation on OSHA’s requirements. 

The COVID-19 pandemic has created many changes in society and at work. For those companies that are still operating, and for those employees who are still working, safety training and in particular mandatory, compliance-based safety training, is a serious consideration.

What’s the best way to complete mandatory safety training, and stay in compliance with OSHA requirements, during this pandemic? In particular, how to do this and still maintain the social distancing requirements of six feet personal separation? And, given the novel status of the COVID-19 virus, the fact that we’re still learning about COVID-19 and transmission routes, and increasing concern and evidence that the virus may be aerosolized and people could possibly be infected by an infected (but asymptomatic) person who is simply talking or breathing, is six feet of separation enough? Is face-to-face safety training a good idea or is it, perhaps, in some way counter to the goal of safety and health during a pandemic?

Can online safety training be used to avoid face-to-face compliance-based safety training or minimize it during the pandemic?

We’ll try to cover these issues in this article, explain what we know about OSHA’s current safety training requirements, and give you some tips for integrating online safety training into your safety training program while still staying in compliance with OSHA regulations in this article.

We wish you all good health and safety during a difficult time. Please feel free to use the comments section to share any tips or information you may have on these topics.

We encourage you to read teh article below, but you might want to know that our own Jeffrey Dalto, a member of the ASSP Z490 committee and a contributor to the ANSI/ASSP Z49.2 national standard for online EHS training, recently talked about OSHA Safety Training Compliance and COVID-19 for the ASSP podcast channel.


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OSHA Releases New COVID-19 Guidance: Discretion in Enforcement when Considering an Employer’s Good Faith Efforts During the Coronavirus Disease 2019 (COVID-19) Pandemic

On April 16, 2020, OSHA released yet another new guidance related to COVID-19. This one is titled Discretion in Enforcement when Considering an Employer’s Good Faith Efforts During the Coronavirus Disease 2019 (COVID-19) Pandemic.

We’re going to encourage you to read the entire guidance, but the excerpt below shows OSHA is giving their field officers discretion on enforcement of violations during an inspection if the employer shows evidence of “good faith efforts to comply.”

During the course of an inspection, OSHA Area Offices will assess an employer’s efforts to comply with standards that require annual or recurring audits, reviews, training, or assessments (see Annex below for some examples).  Compliance Safety and Health Officers (CSHOs) should evaluate whether the employer made good faith efforts to comply with applicable OSHA standards and, in situations where compliance was not possible, to ensure that employees were not exposed to hazards from tasks, processes, or equipment for which they were not prepared or trained.  As part of assessing whether an employer engaged in good faith compliance efforts,  CSHOs should evaluate whether the employer thoroughly explored all options to comply with the applicable standard(s) (e.g., the use of virtual training or remote communication strategies).  CSHOs should also consider any interim alternative protections implemented or provided to protect employees, such as engineering or administrative controls, and whether the employer took steps to reschedule the required annual activity as soon as possible.

The OSHA Safety and Health Topic Page for COVID-19 has become a daily must-read to keep on top of all the new stuff from OSHA re: COVID-19. You might want to bookmark it. Stay safe and healthy, friends!

OSHA General Industry Compliance Guide Button

Free OSHA General Industry Compliance Guide Download

Download this free guide to assist with meeting your organization’s OSHA general industry compliance requirements.

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OSHA Releases Interim Enforcement Response Plan for Coronavirus Disease 2019 (COVID-19)

During the COVID-19 pandemic, things seem to be changing super-quickly. That’s true in all walks of life, and it’s true if you’re trying to keep up with OSHA’s responses as well.

We’re actually a few days behind in noticing that OSHA released a new guidance related to COVID-19 on Wednesday, April 13, 2020 titled Interim Enforcement Response Plan for Coronavirus Disease 2019 (COVID-19).

It’s a longish one, so we’re going to leave you to read it instead of trying to summarize it, although we did touch on some part of it in our newly updated article OSHA, Safety Training & COVID-19.

Stay safe and healthy, friends!


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Adding Online Maintenance Training During the COVID-19 Pandemic

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Companies have been using online training more and more in recent years. But this COVID-19 pandemic, which really became an issue in the United States in early 2020, is making all sorts of companies think even more about using different forms of online training to help transfer knowledge to their employees while assisting employees in the continued development of skills.

Just like any other department, maintenance departments are thinking the same thing, thinking of safe ways to deliver training to maintenance techs while observing social distancing and trying to prevent passing a dangerous viral infection from worker to worker.

In this article, we’ll discuss a few different types of online training in this article and give you some tips for getting some online training to your maintenance techs instead of using instructor-led training.


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What Is Poka-Yoke?

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One powerful idea in the lean manufacturing toolkit is poka-yoke, which can be translated into English as something like “mistake-proofing.”

By designing equipment and work processes to make certain kinds of error impossible, we can reduce error, reduce waste, and improve quality and value.

Although poka-yoke is an important part of lean manufacturing, you can see that it’s important outside of a lean context too. For example, safety professionals often speak of prevention through design, which is clearly a similar idea. So poke-yoka can help you improve efficiency, quality, safety, profitability and even worker morale while increasing value for the customer.

Read the rest of the article to learn more about poka-yoke, an important tool for continuous improvement.


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Developing a Risk-Competent Work Force

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In this discussion with Human Performance Improvement Specialist Joe Estey, we talk about risk at work and risk management in general, about the difference between being a risk-adverse organization and a risk-competent organization in particular, and Joe shares some tips for helping workers to become risk-competent.

Additionally, Joe offers some great resources to learn more, and we’ll provide links to those resources below.

Enjoy the interview in recorded discussion format below and good luck with your own efforts to create a risk-competent workforce that will assist your organizational continuous improvement efforts.

In addition to the discussion about risk-competency below, you might enjoy these earlier discussions we’ve had with Joe as well:

Enjoy the video immediately below. In a little while, we’ll offer a transcript of this discussion as well.


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8 Ways a Learning Management System (LMS) Serves as a Risk Management Tool

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Risk management is an important tool in many different fields: finance, safety, and more.

Risk management is also central to your workplace learning and development efforts, even if you don’t think of workforce learning in that way. But stop and think of all the different risks you’d face if it wasn’t for your workforce learning programs. You might not be able to recruit as many good new employees without one and you might not keep the ones you do recruit as long. New employees would struggle to understand their jobs and it would be harder to teach them new job roles and skills in their career path. You might quickly run afoul of compliance challenges, and without an emphasis on learning, your company might drift into inefficiency, irrelevance, and ultimately out of existence.

One tool your learning program can use to reduce these risks is a learning management system, or LMS. We’ll discuss a few of the ways an LMS can help your organization reduce risk exposure in this article.


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5 Critical Building Maintenance Tasks to Keep Up With

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Our society has changed dramatically over the past few years. Where once, most manufacturing and services were performed via manual labor, we now look to automated machines and robots, instructed by computers, to perform those often-boring, repetitive tasks. And, while we have technologically gained in the arenas of productivity, quality and consistency, we also have lost something. In the transition to automation, our mindsets have changed to where many people believe that computers can “do it all”. That they can replace humans in pretty much any endeavor, and outperform the human, no matter what the task. Someday, this utopian perception may become reality, but for now there still exists a huge majority of tasks requiring human intervention and human comparative thought processes that computers simply cannot accomplish.

This article will present five very critical areas regarding building maintenance that require talents that, as of today, only humans can provide. Now, you may say that these areas are quite obvious, but the fact is, that lack of attention to the items we’ll discuss results in many accidents each year. And some of these accidents are crippling, permanent injuries, while still others are fatalities. If you are a building supervisor or manager, or perhaps a maintenance person, paying attention to the items we’ll discuss will minimize the potential for accidents, and, isn’t that what we all want and strive for – a safe environment for our visitors, tenants and employees?


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Creating Performance Support While Converting ILT to Online Training During COVID-19 (With Guy Wallace)

In this recorded video discussion, we talk with Guy Wallace about human performance technology (HPT), also known as human performance improvement (HPI), and in particular, about performance support, which is also called guidance and workflow learning, and which can include things like checklists, videos delivered online, helpful tips embedded into software programs, and more.

In particular, Guy talks about the importance of considering creating performance support during the COVID-19 pandemic, when a lot of people in L&D are trying to quickly convert instructor-led training materials to online training.

We appreciate Guy’s insights and contributions, both to this discussion and to the field in general. And we hope you’re all safe and healthy.

(Typically, a coworker makes a split-screen image of myself and of the subject matter expert to function as the thumbnail image for these videos, but there’s a pandemic going on, we’re short-staffed, and so I apologize to Guy that I just went with the default image YouTube applied to the video below). 

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OSHA Releases Expanded Temporary Enforcement Guidance on Respiratory Protection Fit-Testing for N95 Filtering Facepieces

On April 8, 2020, OSHA released an expanded temporary enforcement guidance on respiratory protection fit testing for N95 filtering facepieces that applies to all industries during the coronavirus/COVID-19 pandemic.

This new guidance expands an earlier guidance, published in mid-May, that applied only to the healthcare industry.

Please read the new, expanded guidance to learn more.

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