How to stay in compliance with employee training
By Steve Guglielmo, Marilyn Dempsey, Michael Dodd and Tom Badstubner
Your employees are the lifeblood of your organization. In order to ensure that they can do their jobs correctly and safely, it’s vital to provide continuous training. But this can be a daunting and time-consuming task. How often does this training need to be done? When does it need to be recertified? How can the training be presented in a way where the employee can retain it? And how can this training be continually reinforced each and every day? Welding & Gases Today spoke with three of GAWDA’s Consultants to get their perspective on this important topic. Marilyn Dempsey is GAWDA’s newest Consultant, advising members on topics related to DHS, EPA and OSHA, Michael Dodd is GAWDA’s DOT Consultant, and Tom Badstubner is GAWDA’s FDA, Medical, and Specialty Gases Consultant. The following is a transcript of a conversation regarding training best practices.
Welding & Gases Today: Can you describe some best practices with onboarding new employees and getting them up to speed with the respective regulations in your agencies?
Tom Badstubner: We do have a sample procedure in the Members-Only Section of GAWDA.org. The first thing you need to have is a list of all the training that is required for new employees and then a list for new people in each job position. The new employee and job-specific training should be predefined. You then go through the training list and have a qualified person with the trainee until they’re fully trained.
Mike Dodd: We’ve got these wonderful lists. But if you try to follow the lists and you try to do it for all the agencies, this poor employee is going to be sitting in training classes for the next two weeks solid. And you will lose them. He or she will be hit with so much information so quickly, that none of it is going to stick. So, I’m somebody who likes to go back and say let’s do a little bit now. And they’re going to work with a trained employee. They need to have sort of a mentor that is with them for a week or two to show them the ropes and keep them out of trouble. And that way, they can feed it to the new employee a little bit at a time and not in a massive onslaught. I know it’s not exactly how the regulatory agencies want you to do it, because most of them say “on or before exposure.” Well, that’s almost impossible. But if we just have them stick with an experienced employee who can keep them out of trouble, I’ve found that if you can get the employee through the first six months of not getting an injury, you’ve usually got it made. After that, it seems to work pretty well.
WGT: So, the trick is just getting them through those first few months.
Mike: Yes, get them through the first six months injury-free by keeping a close watch on them, working closely with other employees and it seems to work.
Tom: It’s important, because the first 12 months are the highest injury potential period of a person’s entire employment.
Marilyn Dempsey: It’s funny you say that, because when I studied that with our statistics at Tech Air, I found that you’re right. It’s the very new employees and then the ones who have been there the longest. The complacent ones. So that goes into continuing training. I totally agree with everything Mike and Tom are saying. I do think it can be done, because it’s actually what I used to do. And that is, we had a schedule set out for day one, week one, month one. The first day is all about sitting down and making sure that they understand and fill out all the HR forms and you get them into their employee safety training. The very beginning of it is hazard communication. That’s how to read a label. And what our products are. Is it an oxidizer, a flammable or an inert? A lot of people come to our industry and they don’t know how to roll a cylinder or use a cylinder cart. So, you can use those first. You do the employee safety training and then you go out and practice a little bit. Do a little bit more practical stuff. The one thing I feel people get injured doing is handling the cylinders. Crushed fingers or banged fingers, strained shoulders, dropping cylinders on their feet, not strapping cylinders to cylinder carts. Those are things that you can really entrench into a new employee. And the whole thing about mentoring, getting a senior person. Have the senior person and the new employee buy into having a better safety culture. The more input you can get, the more mentors you can get around this newbie, the better team you’re going to have overall.
Tom: I completely agree. That’s the formula for success. For example, when I was training new employees, I found over and over that people just do not want to drop a cylinder. They don’t want to look bad in front of their fellow workers. And mishandling out-of-control cylinders is where people get hurt. So, one of the exercises I would do is tell them to drop a cylinder. We would get over the natural feeling of grabbing a falling cylinder. The cylinder is going to be fine. But if the employee chases that cylinder with his back, they won’t be fine. So, effective and safe practice can build a new habit.
Marilyn: That’s so true.
WGT: Once the employee is comfortable and up to speed, how do you avoid that complacency that you mentioned? “I’ve done this a million times and never gotten hurt. Why would the one million first time be different?” How do you avoid that?
Marilyn: I think you have to go back to your statistics. You might not have had something happen like shearing off a valve. But you can pull up the numbers. “I know this other distributor that had this and this is what happened.” And you can show them either a piece of a cylinder that ruptured or what a bad valve looks like. What is the difference between the valves or between a good and a bad strap? The more you can put the older group in the responsibility or mentoring position, the more likely you’re going to have that older group take care of the new group and change their own attitude.
WGT: Does that keep them more engaged?
Marilyn: It definitely keeps them more engaged because it’s not a top down mentality. It’s about saturating the entire business structure. You have to have top management walking around doing this, and you have to commend people when they stop another coworker from doing something that is not safe. Not to punish the other worker, but quietly take the person who mentioned it aside and say, “Thank you for looking out for him. That was really great.” Engage everybody. And if you can get your CEO or your CFO walking around and out there talking to people and asking, “What do you feel is your challenge?” The more engagement that you have from top management all the way through the ranks, the more likely you’re going to have people buying into your safety culture.
Tom: If you have either a written procedure or a job safety analysis (JSA … call Marilyn if you want to know about JSAs) it helps to make a copy of that written procedure/JSA. And then go out in the plant and review the that procedure with the employees who need to use it. Maybe it’s once a year or once every three years. This becomes not only a training experience, where you actually do the procedure, but it’s also a way to see how the procedure might get improved. Because they’re the experts. If they’re doing the job the right way, they’re absolutely the experts. And they might have some suggestions for ways to improve that procedure. I’ve found that taking a written procedure out and using it as a training tool accomplishes so much good. For the new guys and the experienced ones.
Marilyn: It shows that you value their opinion when you’re writing a new procedure. We talk about how we’re going to engage people. There’s a positive way, which is what we’ve been talking about. But there’s also a negative way that we want to stay away from. And then there’s reinforcement. Training is not only when the inspector is knocking at the door. You have to show that you’re invested in training. You can have a monthly training session and you can get face-to-face with your employees and not only give them a safety topic but also engage them by asking, “What is going on in your job? What difficult deliveries are you having? What equipment is giving you headaches?” That way, you’re less likely to have an issue further down the line.
WGT: How can the GAWDA consultants be used in this process?
Mike: One of the things that I do a lot of for membership is a lot of initial and refresher training. Most of the DOT items, almost all of them, are set up on a required every three-year basis. A lot of times, I do a train the trainer training and then the members do their own training in the future. Or they come to our seminars and we do the train the trainer at the seminars. But most of our stuff is on some sort of a frequency. And one thing I really wanted to cover is the fact that most people will do a good job of training if they just remember to do it. And they know who needs to be trained. So, one of the things that we stress is having some sort of a spreadsheet where they keep track of all the required training subjects, the employees and the due dates. When are these next training items due? If they just look at that once per month and see where they are, it will pretty much tell them what they need to do and when they need to do it. Coming up with the materials to do the training? That’s easy. That’s where the consultants come in. And we usually bring them nice, simplified programs. If you do these things, this will accomplish your training. But we can’t be there to remind them every month: this person is due, this person is due, and this person is due. Initial is easy. There’s a list for that. It’s the follow-up later that they need to be reminded of.
Tom: That’s where we see violations from the agencies as well. The follow up training.
Mike: That’s exactly right. And it’s so easy to do if they have a system in place to remind them.
Marilyn: That’s very true. One thing that I found in my previous job was that we had to define the roles that people had. You have drivers who fill cryogenic cylinders or propane or who even work in the fill plant. So, you have to be specific about where they fit in in your training matrix. And then you can plug them in. And then you look at who is due.
WGT: Where do you see companies slip up most often? Any common missteps?
Mike: I see two places. I don’t see the refresher training happening on time. And I see people getting busy and sometimes they don’t do that new employee training quite soon enough. With the DOT inspections, when they walk in, I almost guarantee you that with training they will catch companies in one of two places. Either they forgot to do the refresher, or they forgot to do the new person. A lot of companies have their refresher training set up on a schedule of once per year or once every two years. But they forget to do the new person. And when I’m doing my DOT audits, I’m going to walk in and say, “Let me see a list of your employees,” I’ll note their start date. And then I say, “I’d like to see the documentation for the training for this person right here.” And that’s where you’ll see people realize “I haven’t done that person yet.”
WGT: You said in the last column that agencies will go out of their way to look for that, right?
Mike: Oh yeah. They know where they can catch people. And it’s usually the new employee who they haven’t gotten to yet. They do a great job on the refresher and forgot to do the new guy.
WGT: When that happens, then what? Is it one of those things where you can make a good faith effort, “I’ll get them trained right away,” or is that a penalty the moment it’s noticed?
Mike: As far as from the regulatory agency? In DOT, I’ve noticed that there is an awful lot of discretion. Sometimes the inspector will say, “Just get that person trained. It looks like you’re doing a great job of training, everybody is up to date, you just forgot this one person.” You can get that kind of inspector. Or you can get the inspector who says, “Got ya!” And that’s a penalty. You might have a 99% program, but you forgot the new person. It’s still a penalty. So, you never know which inspector you’re going to get.
WGT: Marilyn, as somebody who was recently on the other side of this coin, what did you find was most difficult in this regard?
Marilyn: We had a very good plan on how to train people. The monthly training was simplified. Where there were issues was not in upper management or on the floor. It was middle management. It was the store manager who might have 25 orders for this one truck saying, “I don’t have any time this month to go and get this person trained.” It’s a matter of keeping up and making sure that people were actually trained. Because that’s exactly what the inspector will do. I had OSHA come in a few times and the way that I did not get cited is that they looked at our training records and our training program and they said, “Ok, thank you very much, Mrs. Dempsey.” And then they left.
Tom: Because you were organized.
Marilyn: That’s the whole thing. Being organized.
Tom: I’d like to back up a bit. Mike identified ways for people to get trained and problems that might happen. Another problem that I see, particularly in the medical gas area, is when a seasoned employee trains a new employee on something like how to fill oxygen. But they don’t train them to any written standards, they just train them as they remember being trained by the guy before him.
WGT: This is how we’ve always done it.
Tom: Right, this is how we do it. And then, in a couple of generations of workers, the practice is actually far away from the approved practice. By having a written procedure that you train to, you can eliminate that. It can eliminate those random innovations that always happen in the work process.
WGT: Things are evolving all the time. If you have a written standard, how often does that need to be updated?
Tom: The FDA requires a three-year review on certain things like risk assessments. I think a three-year review on written procedures would not be overly burdensome and I think it would help a lot. The DOT requires HAZMAT training every three years, right, Mike?
Mike: Every three years. Almost everything in DOT is every three years.
Tom: So that would be kind of a perfect time to do it. I think I would train the person initially using written procedures and then review those procedures every three years.
Marilyn: Tom, you hit on something that we went through, especially with FDA inspections, which is that the inspector will go out there with your SOPs and check the pumper. So, it’s very good if the manager can do an annual checkup on how everybody is following the procedures. And if they’re not, why not? Maybe it’s time to tweak the procedures. Or maybe it’s time to have a chat and say, “The reason why we do it this way is…”
Tom: Yeah, the FDA treats the failure to follow your own procedures with the same amount of seriousness as not following their regulations. And there have been some very serious warning letters issued for failure to follow procedures. Even sometimes when those procedures were not perfect, the FDA still cited for failure to follow those procedures. They really didn’t cite the work being done. They cited the failure to follow procedures.
Mike: Now it’s a question of presentation of the training. We can talk about the frequency; we can talk about the follow up. But now let’s talk about how it’s actually done. So, a couple of thoughts. I’ve found that all-day training sessions, or what has come to be known as “birthday training,” every year doing a bunch of things at the same time so you can get them checked off the list, that’s very ineffective, to me. It doesn’t seem to sink in or help the accident incident rate. What I’ve found is that if you can keep the training sessions short but more often, versus long and far apart, you’ll have more success. I’ve seen some very good companies with very good safety culture have what I call a “toolbox meeting” or a lunchroom meeting. First thing in the morning for about 5-10 minutes, talk about a quick safety topic and the needs for the day, and it’s a very quick way to gather everybody up and discuss. Then you’re out the door. That seems to work really well. One more thing, we’re rapidly approaching the electronic age. The days of sitting down in a classroom and having a teacher in front of you is little by little going away. It’s still very valuable. That person looking you in the eyes is very helpful. But we’re seeing a lot more online training. There are a lot of different avenues. I would just hate to see anybody get trapped into doing one kind of training. It really helps to mix it up. It keeps the employee interested to do different methods and you get more feedback, especially if you do in-person training.
Tom: Every mode has its benefits. Sometimes you’re just simply trying to pass on some information and the online meeting is good for that. Sometimes you really need to focus on a change in behavior or new competencies, and face-to-face is good for that. CGA has some amazing e-learning modules. We have GAWDA University. These have their place. They make good sense when you’re retraining people on an annual basis.
Marilyn: I agree that different formats have their pros and their cons. I am not a big fan of all-day training. You generally start losing people after 20 to 30 minutes. They need a mental break from the screen or from you or from whomever. Sometimes you have to have those long training sessions. Hazard communication you can’t boil down to 20 minutes. I think one of the things that all of us do is make things as simplified and digestible as possible. And I’m so excited to be working with these guys because they have the same type of training that I want to do. Let’s demystify these things.
One last thing I wanted to add is that training isn’t just a requirement. It’s an investment in your people. That’s how we’re going to keep people and grow people and keep them safe.
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