This material is for training purposes only. Its purpose is to inform Oregon employers of best practices in occupational safety and health and general Oregon OSHA compliance requirements. This material is not a substitute for any provision of the Oregon Safety Employment Act or any standards issued by Oregon OSHA. For more information on this online course and other OR-OSHA online training, visit the Online Course Catalog.

MODULE TWO: PPE TRAINING REQUIREMENTS

Introduction

You are told to mix a certain chemical with water to use as a cleaning agent to wash down your company trucks. You check out the chemical. It looks like water, doesn't feel any different than water...so you assume PPE isn't really necessary. So, you go about washing the trucks. Your hands and arms get pretty wet with the solution you've mixed, but, heck...no pain, no sting...must be safe. No worse than water, right? Wrong, very wrong.

You've been using a mixture of hydrofluoric acid and water. By the time you get home your arms are hurting like crazy. You hurry off to the hospital, but by the time you arrive, it's too late. The hydrofluoric acid has penetrated your skin on both of your arms, clear through to the bone. Fluorine ions have replaced calcium ions in the bone, effectively turning it into a sponge-like consistency. But, you're lucky, only one arm must be amputated. The doctors were able to save the other arm.

This scenario would not have occurred had you been properly trained in using PPE. The PPE standard mandates that the employer must provide training to each employee who is required to use Personal Protective Equipment. But, what is effective PPE Training. What methods work, and what are the goals of training PPE? We'll try to answer these questions, and others, throughout this module so that you'll be better able to participate in, conduct, or manage PPE training that is beneficial to the employee and cost effective for the employer.

What subjects must be trained?

According to the standard, to meet the minimum training requirements, each employee receiving PPE training must be trained to know at least the following:

When PPE is necessary;
What PPE is necessary;
How to properly don, doff, adjust, and wear PPE;
The limitations of the PPE; and,
The proper care, maintenance, useful life and disposal of the PPE.
So far, we meet minimum Oregon OSHA requirements... but one very important element is missing:
The PPE standard does not specifically require education on "why" PPE is necessary
So, why is this element so important? Because study after study tells us the most common reason employees don't follow rules in the workplace is because they don't know why the rules are important.

Educate the "why" as well as train the "how"

It's important to understand that whenever we conduct PPE training, educating the "why" and training the "how" must always occur. If we neglect the educational component, we jeopardize the long-term effectiveness of the overall training.

The first five elements in the list describe the what, when, and how about PPE use. The goal is to increase both knowledge and skill so that the employee is better able to properly use PPE. The methods used to train the employee is primarily discussion and demonstration. To measure knowledge and skill, the instructor usually tests the employee by asking them to do something.

The final "why" element addresses the importance of using PPE and what the consequences of behavior (compliance and failure to comply) will be. The natural consequences include some form of resulting injury or health to the employee. The system consequences describe the nature of the discipline or recognition that will result from performance. The goal of this last element is to increase employee motivation to use PPE so that the employee is more likely to use PPE properly. The method used to educate is primarily classroom lecture or discussion. To measure motivation, the instructor usually tests the employee by asking them to write or say something.

Demonstration is the key

Before an employee is allowed to do work requiring PPE, the employer must require each affected employee to:

Demonstrate an understanding of the training elements listed above, and
Demonstrate the ability to use PPE properly.

Demonstration is really the most common and probably the most efficient method to determine employee knowledge and skills. How does the employee demonstrate an understanding of the six PPE training subjects listed above? Simple, their level of knowledge is measured by asking the employee questions similar to those below:

What are the PPE required for your particular job?
When is the PPE required to be used in your job?
What are the possible defects your PPE might have?
How do you properly care for and maintain/store your PPE?
What is the useful life of your PPE?
From what hazards does the PPE protect you?

The form of the "test" may be either written or oral. In addition to the oral or written test, the standard requires some kind of method that provides an opportunity for the employee to demonstrate adequate skills. Here is a simple training strategy that ensure the student will have an opportunity to demonstrate.

On-The-Job Training Strategy

On-The-Job (OJT) is probably the most common training strategy used in the workplace and for a good reason. It's can be very effective because it tests both knowledge and skills during the training process. Let's take a look at the OJT steps:

Step 1. Introduction. State and discuss the learning objectives and answer any questions the employee may have. Discuss the acceptable standards of knowledge and performance. Tell the trainee what you’re going to train. Emphasize the importance of the procedure to the success of the production/service goals. Invite questions. Emphasize the natural and system consequences of their performance. The natural consequences describe the hurt or health that automatically results. The system consequences are those consequences the organization applies as a result of an employee's performance; discipline or positive recognition.

Step 2. Trainer tells and does. In this step the trainee becomes familiar with each work practice and why it is important. Review the initial conditions for the procedure. Demonstrate the process, carefully explaining each step as you go. Answer questions and continue to demonstrate and explain until the employee understands what to do, when and why to do it, and how to do it.

Trainer: EXPLAINS and PERFORMS each step.

Learner: OBSERVES each step and QUESTIONS the trainer.

Step 3. Leaner tells - Trainer does. This step is necessary when exposure to hazards inherent in the procedure could cause serious harm. It protects the trainee because the trainer performs the procedure. The trainee explains the procedure to the trainer, while the trainer does it. This gives the trainer an opportunity to discover whether there were any misunderstandings in the previous step. The trainee also responds to trainer questions.

Learner: EXPLAINS each step and RESPONDS to questions.

Trainer: PERFORMS each step and QUESTIONS the trainee.

Step 4. Leaner tells and does. The trainer has the trainee do it. The trainee performs the procedure but remains protected because the trainee explains and gets permission to do the step before proceeding to do it.

Learner: EXPLAINS, GETS PERMISSION and then PERFORMS each step.

Trainer: GIVES PERMISSION, OBSERVES each step and QUESTIONS the trainee.

Step 5. Conclusion. Recognize accomplishment - “Good job!” Reemphasize the importance of the procedure and how it fits into the overall process. Tie the training again to accountability by discussing the natural and system consequences of performance.

Step 6. Document. Training documentation should be more than an attendance sheet. Be sure to include the information below to properly document (certify) training in specific safety procedures and practices. Include all of the following even though OR-OSHA rules tell you all that's required is name, subject, and date.

Trainee’s and trainer’s name.
Date of training.
Subject(s) being trained - procedures, practices, related policies, rules, etc.
Certification - trainee and trainer signatures.
Trainee statement of understanding and intent to comply.
Trainee statement that he/she was provided opportunity to practice.
Trainer statement that testing of knowledge and skills was conducted.
Trainer statement that student demonstrated adequate knowledge and skill.

Step 7. Validate. At some point in time after the conclusion of the OJT session, observe and question the employee to validate that the training has been successful and that the employee has developed a proper attitude related to the work.

When is retraining required?

When the employer has reason to believe that any affected employee who has already been trained does not have the understanding and skill required by the PPE standard, the employer must retrain the employee. Circumstances where retraining is required include, but are not limited to, situations where:

Changes in the workplace render previous training obsolete; or
Changes in the types of PPE to be used render previous training obsolete; or
Inadequacies in an affected employee's knowledge or use of assigned PPE indicate that the employee has not retained the requisite understanding or skill.

Who should conduct the training?

This is a very important question. Whoever the person training PPE is, he or she needs to be an expert who not only understands how to use PPE correctly, but has a thorough understanding of the importance of doing so. It's critical that the employee understands the importance of wearing PPE, not only for their safety, but their "continuing employment."

If it isn't in writing...it didn't happen

As with any safety program, it's important to both the employee and employer that PPE training is properly documented. To meet minimum rule requirements, the employer must verify that each affected employee has received and understood the required training through a written certification that contains the name of each employee trained, the date(s) of training, and that identifies the subject of the certification.

However, when it comes to documentation of PPE training, it's a good idea to go beyond the minimum requirements stated in the standard to make sure the employer can demonstrate (prove) they have met or exceeded their legal obligations with respect to safety training.

Solid PPE training documentation will contain the following elements:

A statement by the employee that they have received training by the employer on the six subjects listed above, and that the trainer has demonstrated proper use of the PPE and answered all employee questions about the PPE satisfactorily.
A statement by the trainer that, through oral/written test, the employee has satisfactorily demonstrated an understanding of the subjects covered during training, and has, through practice, demonstrated the ability to properly don, use, doff, care for, and maintain the PPE.

Below is a one example of training documentation. Your training documentation may look different, but it's very important that both the employee and trainer sign and date the document.

Training Subject ______________________ Date _________ Location _______________
Trainee certification. I have received on-the-job training on those subjects listed (see lesson plan):
This training has provided me adequate opportunity to ask questions and practice procedures to determine and correct skill deficiencies. I understand that performing these procedures/practices safely is a condition of employment. I fully intend to comply with all safety and operational requirements discussed. I understand that failure to comply with these requirements may result in progressive discipline (or corrective actions) up to and including termination.

Employee Name Signature Date

______ ______ ______

______ ______ ______

Trainer certification. I have conducted orientation/on-the-job training to the employees(s) listed above. I have explained related procedures, practices and policies. Employees were each given opportunity to ask questions and practice procedures taught under my supervision. Based on each student's performance, I have determined that each employee trained has adequate knowledge and skills to safely perform these procedures/practices.

_____________
Trainer Name __________________
Signature __________________
Date

Last Words

Remember, PPE training is absolutely critical to an effective program. Effective training will likely prevent serious injury or even a fatality which makes it all worthwhile. OK, let's complete the review quiz.

MODULE Quiz

11. According to the Oregon OSHA standard, employees shall be trained on all of the following PPE subjects except:

a. How to don and doff PPE
b. When PPE is necessary
c. What PPE is necessary
d. Why PPE is necessary
e. The limitations of PPE

12. Knowledge and skills related to the use of PPE is best measured by:

a. Oral or written tests
b. Demonstration
c. Written tests and demonstration
d. Lecture and group exercise

13. Before an employee is allowed to do work requiring PPE, the employer must require each affected employee to demonstrate an understanding of the training elements and the ability to use PPE properly:

a. True
b. False

14. Supervisors must make sure employees are retrained if they demonstrate inadequate skill in using PPE.

a. True
b. False

15. Why is it important to adequately document PPE training?

Congratulations on completing the this module! Training is certainly key, but remember, the safety culture must support the training, or the training will fail. Continue on to the next module to learn more about eye and face PPE requirements . If you have any questions or comments, just drop me an email at email.

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