Qualitative Differences in OSHA Outreach Training Course Providers

Qualitative Differences in OSHA Outreach Training Course Providers

Are you thinking about attending an OSHA outreach course or sending your employees to one? If so, you are not alone. Here are the answers to some commonly asked questions.

The Outreach Training Program is OSHA's primary training program for employees. Through this program, OSHA authorizes qualified safety and health professionals to conduct training for workers in both construction and general industry. Employees who take such training receive an OSHA-issued card documenting their successful completion of the course. More than 1 million trained safety and health professionals received such cards in the past 3 years.

Enrollment rates in OSHA's Outreach Training Program have skyrocketed during the past 15 years. In 1992, the OSHA Training Institute's (OTI) train-the-trainer courses began to be offered by additional education centers (OTIECs). Today, there are 26 OTIECs, which are the principal distribution channel for the outreach trainer courses. These courses authorize trainers to teach the well-known OSHA 10-hour and 30-hour outreach courses, with separate authorizations for trainers in general industry and construction. These relationships are shown in Figure 2.

WHY TAKE A COURSE?

Many students or employers are motivated to take an outreach course by the issuance of course completion wallet cards. Construction contract criteria may require some or all jobsite employees to carry these cards. Some employers believe that their companies will be more OSHA-compliant if supervisors or employees earn these cards.

At the management level, the courses are popular among those responsible for safety or regulatory compliance but who have little related education or experience. Safety professionals sometimes want other managers in their companies to take a course to improve understanding and cooperation with their initiatives. Most managers want their companies to avoid the negative publicity that sometimes is associated with poor compliance.

Benefits claimed by some trainers, such as a safer workplace, citation prevention and lower insurance costs, assume a number of other conditions in addition to course attendance.

WHAT'S IN A COURSE?

OSHA 10- and 30-hour-course authorized trainers are required to follow guidelines published periodically by OSHA's Directorate of Training and Education (DTE). The primary requirements govern topics that can be taught and the time allotted to each subject.

Most of the course topics are related to OSHA subparts or sections (commonly called “standards,” although that is not accurate) from the Code of Federal Regulations that pertain to the applicable industry sector. All courses require 1 hour (2 hours for the 30-hour courses) to address the OSH Act of 1970, the inspection process, recordkeeping basics and the rights and responsibilities of both employers and employees, including whistleblower protection and the General Duty Clause. Additional requirements recently were added to include OSHA's Web site, 800-number and other resources.

In the 10-hour general industry course, 5 additional hours are designated for specified, commonly applicable standards (e.g., electrical, exit routes, fire protection, hazard communication, personal protective equipment, walking/working surfaces). Two more hours' topics must be chosen from a short list of eight standards and topics (e.g. ergonomics, fall protection, safety and health programs). The remaining 2 hours may be spent on any applicable hazards or policies, including expanding upon the previous topics.

The 10-hour construction course is similarly prescribed: 5 1/2 hours on specified topics and 2 hours of short- list topics, with the remainder of time being discretionary. Two of the prescribed hours now consist of OSHA's “Focus Four Hazards,” the four primary causes of construction fatalities: fall protection, electrical, struck by and caught in/between.

While topic selection is largely prescribed, instructors have latitude within the listed topics to accomplish what is important to their audience. For example, the subpart for Fire Protection includes a number of fire suppression technologies, but if training is limited to a single facility, the course could focus on the system used at that facility.

For subjects where a more current consensus standard exists on a subject, it may be appropriate to supplement the OSHA standards-based content with best practice information.

HOW DO INSTRUCTORS BECOME AUTHORIZED?

Before outreach trainers can teach these courses, they must meet prerequisite course completion and authorization maintenance criteria. The coursework involves the equivalent of a 30-hour outreach course and a week-long trainer course with a final exam. Participants must have at least 5 years of safety experience or a recognized safety designation. Once authorized, instructors are required to attend a 3-day update course every 4 years.

Although these criteria may screen out some unqualified instructors, they do not guarantee the instructor has the training skill to develop and deliver high quality outreach courses or the knowledge depth to field student questions in a course. Some outreach instructors are unaware of the 4-year update requirement and learn only when they apply for student completion cards that they no longer are authorized to teach the course.

Currently, approximately 40,000 authorized trainers meet the criteria described above. OSHA estimates approximately 13,000 of these are “active,” meaning they will conduct outreach courses during their 4-year authorization. Given that 80 percent of the students trained in fiscal year 2007 were in construction, most of the authorized trainers likely are in that sector, although some instructors are authorized in both construction and general industry.

RESOURCES FOR TRAINERS

Over the years, OSHA has increased the audio-visual materials available to outreach instructors. Provided PowerPoint presentations have improved, but are superficial and have dated visuals. The agency could provide more valuable materials that relate hazard concepts to the standards' requirements, have current imaging and be adaptable to management, supervisory and employee audiences. Similarly, videos available to trainers from OSHA's Resource Center Loan Program are limited to VHS format and date mostly from the 1990s. Alternative commercial sources may produce a higher quality learning experience.

Among the instructor tips offered in the DTE guidelines is to design the course so students “can relate … because the trainer uses examples, pictures and real-life scenarios from their work place …” This is perhaps the greatest qualitative difference among trainers. Using stock photos and off-the-shelf presentations is unlikely to connect with an audience as well as photos from their facility, highlights from their written safety programs and discussions of their incident experience. Perhaps the greatest threat to maintaining student interest arises from covering material not applicable to the audience, even if it is OSHA-provided and fulfills DTE's course requirements.

DO OUTREACH COURSES ENHANCE COMPLIANCE?

According to the current trainer guidelines, “Outreach courses are designed to be presented to workers, therefore they must emphasize hazard identification, avoidance, control and prevention, not OSHA standards.” This may surprise those who attend an outreach course hoping to learn what OSHA requires of employers. Students interested in learning what the standards require, what OSHA actually enforces and how to navigate the regulatory texts will need to choose a trainer who explicitly provides that knowledge and skill.

Understanding OSHA standards' requirements involves more than reviewing the rules. Arranging the information intuitively and consistently across subjects is more effective than following the structure of a rule itself. Calling out key decision points, especially where the standard is vague, helps students know what they need to do more than simply regurgitating the standard's text.

For most general industry sections (standards), citations usually are clustered around only a few specific requirements within each rule. In fact, proprietary research has found that over 80 percent of the federal and state plan citations consistently are associated with only 25 sections (standards) and among those rules, more than half of the violations relate to a total of approximately 80 paragraphs of the Code of Federal Regulations. Highlighting those paragraphs helps students prioritize their companies' compliance efforts.

While not every student in an outreach course will need to be able to find information in the OSHA standards, higher quality courses will introduce this skill. Enhancements may include teaching the unique outline structure used by the Office of the Federal Register, providing students with practical exercises finding information in the regulatory text and explaining the other documents that impact compliance such as interpretations and directives. Providing students with copies of the standards, especially from commercially available sources that indent and color code the different orders of heading, signifies a high level of course quality.

OTHER CONSIDERATIONS

Although one instructor is permitted to teach the entire course, remember that the instruction time is a full 10 hours (or 30 hours!). Do you watch your favorite TV show for that long? Now imagine spending that long listening to an instructor covering something you may find less engaging. While having a single instructor may reduce the cost of the course, it is hard to imagine the learning outcomes will be as effective as including two or more instructors.

Similarly, the timing of the course should be broken up over at least 2 days for the 10-hour course. Especially for audiences not accustomed to sitting in a classroom, the instruction time should be spaced to reduce fatigue. While it may be tempting to fit a 10-hour course into one day, that duration exceeds participants' ability to retain the information.

Handouts and other tangible take-aways are up to the trainer's discretion. DTE's guidelines indicate that the materials trainers receive in their classes “are not designed for outreach students,” but students should be given at least a fact sheet with key points. For example, providing students with copies of the slides used in the training and supporting reference documents is an enhancement.

WHAT FORMATS ARE AVAILABLE?

Online training sources increasingly are available in addition to the traditional instructor-led format. Online courses offer the advantages of lower cost and delivery flexibility, but have the limitations of the generic approaches mentioned above. Students who simply want to obtain a card with the least trouble may want to pursue this option.

At the time of this writing, OSHA has accepted seven providers to deliver the 10-hour courses for construction and general industry, although other institutions may “host” courses using these providers — as eight OTIECs do. Thirty-hour courses are available online for construction and general industry. According to OSHA's February 2008 fact sheet, Outreach Training Program, less than 5 percent of cardholders have taken their courses on-line.

For options related to instructor-led training, DTE allows teleconferencing (with permission), spreading the course over 6 months, using guest trainers and adding 20 hours to a prior 10-hour course to complete a 30-hour course.

Whether you want to want to attend an outreach course, engage a trainer to tailor a course to your company or help your employees to earn completion cards, the qualitative differences-summarized in Figure 3 should help you make an informed selection from among the 13,000 currently active authorized trainers.


David D. Glenn, CSP, is vice president, senior risk management consultant with Wachovia Insurance Services in Chicago. He holds a B.A. in liberal studies from the University of Notre Dame and an M.S. in industrial management from Northern Illinois University. Glenn has been an authorized general industry outreach trainer since 1996.

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