OSHA Standard: 1926.35(e) Employee Emergency Actions Plan
Frequency: As Conditions or Roles Change
Training Style: 10 or fewer employees may be communicated. 11 or more requires a written plan with documented training.
Location: The written plan shall be kept at the workplace and made available for employee review.
Employer Responsibilities: Before implementing the emergency action plan (EAP) the employer is responsible to designate and train a sufficient number of employees to assist in the safe and orderly emergency evacuation of employees. The employer is required to review the EAP initially when the plan is developed, whenever the employee’s responsibilities or designated actions under the plan changes, and whenever the plan is changed. The employer is also responsible to review the plan with each employee upon initial assignment those parts of the plan which the employee must know to protect the employee in the event of an emergency.
Employee Responsibilities: Employees are responsible to know the role that are assigned and the task(s) related to that role.
Summary: The hardest thing about a construction site is that the structure is continuously changing as construction goes on. Therefore, it is important when employees first arrive to the site they are instructed on the EAP. Furthermore, as conditions or employees change the plans needs to be updated and trained upon to ensure compliance with the standard. Another important point is the documentation of training.
Sergeant Safety offers a wide range of services to assist with your emergency action procedures. For one, Sergeant Safety can create a custom Emergency Action Manual and provide training on that system. Emergency Action Plus can provide a notification system for an emergency actions on the jobsite. And the STAC system offers a perfect streamlined solution to documenting all training and be able to run reports on who doesn't have training. A combination of training and safety resources could prove crucial during an OSHA inspection or during an emergency action event.
I had time recently to reflect on what I had learned while I attended basic training at Fort Jackson, South Carolina. From that reflection I remember three important things echoed from my Infantry Drill Sergeant that hold true in Safety. These lessons are common across the Army, but not as common in the civilian world, so I figured I’d share these wisdoms.
Lesson 1 “Slow is Smooth, Smooth is Fast”
Those words were echoed by my Drill Sergeant while I was attempting to qualify with my assigned M16. When first heard, the expression sounds counterintuitive, how could going slow actually make me faster? Well for starters multiple factors come into play when firing a weapon, breathing, trigger squeeze, and site picture to name a few. But, the slower and smoother that you can handle these factors, better results will occur with increased effective and accurate fire toward the target.
This same principle can be applied to safety in the workplace. All too often we hear the term “hurry up, but be safe.” The implication from these terms is get the job as quick as possible with whatever tools necessary. However, many accidents and injuries can be prevented if the worker uses a slower, but smoother pace of work and constantly thinking and pre-planning for the next step and potential hazard.
Lesson 2 “Stay in Your Lane”
Not to get too bogged down in Military tactics, but essential while assaulting a position, the group assaults forward walking in your assigned “lane.” This lane is a straight line that you walk in, you do not deviate left of right as you might walk into the firing lane of your battle buddy. The good thing about staying in your lane is that you know exactly what sector of fire is your responsibility. It sounds easy enough, but walking in a straight line with obstacles, like thorns and bushes, creates hazards. Therefore, effective training is needed to ensure this concept is maintained.
This same concept can be applied to new workers trying to learn to stay in their lane. However, obstacles and hazards always present themselves. Studies have found that new employees are SIX Times more likely to be injured in the first month, than workers with more than one-year experience. So, effective safety and task training is essential to ensure they know their roles and responsibilities. An effective way to do that is through new hire employee orientation and using a mentor system.
Lesson 3 “Get Smart or Get Strong”
This concept seems simple, learn from your mistakes and the less time you will be in the front-leaning rest position (the push-up). Unfortunately, with thrown into a random group of people, sometimes people learn at different paces. And for my basic training platoon we got stronger than smarter.
In the workplace having smarter workers is far superior to “stronger” workers. A worker that relies on strength alone will eventually overexert himself/herself. For injuries that lasted over 6 days, overexertion (lifting, pushing, pulling, holding, carrying or throwing) was discovered to be the reason for 25.3% of the injuries. The direct cost alone of these injuries was $15.1 billion! A simple way to avoid these injuries is to be smarter; use proper lifting techniques, ask for help when lifting, and use mechanical equipment to aid in lifting that requires little to know exertion. So, don’t just rely on getting stronger, focus on getting smarter.
Although simple, remembering these three basic principles can be applied to the culture of your safety program and hopefully press the mindset to stay safe and remember the lessons of those before you.
Training has become a strong focus recently in the construction industry to reduce accidents and injuries. Studies have proven that training not only provides a more competent workforce, but also a safer work environment. Another motivating factor is fines from the result of OSHA citations. In the 2017 top 10 list, 4,174 of the citations were training related. If those were all compiled into one standard, it would have been the 3rd most frequently cited standard in 2017. But, when is training required? When is refresher training required? What documentation is needed? What resources are available?
When is Training
Most people are familiar with, and already have training programs for, aerial lifts, rigging & signaling, and powered industrial trucks. But, just to name a few others, hand & power tools, stairways and ladders, occupational noise exposure, fire protection, and employee emergency action plans also require a written training program.
What about earth moving equipment, golf carts, and other equipment with no direct OSHA standard? 1926.20(b)(4) states that “the employer shall permit only those employees qualified by training or experience to operate equipment and machinery.” This proof of competency is accomplished through the creation of a written training program. The focus of this program is the recognition and avoidance of hazards and unsafe conditions related to the task. Elements needed in the program include the type of instruction, practical training, and evaluation methods used. Each employee that could be assigned that task or exposed to that hazard must be trained, if not that could be considered a separate violation. It is the responsibility of the employer to document and prove competency. Depending on the type of training, toolbox talks can also be used.
When is Refresher Training Required
Refresher training can be broken down into three categories: OSHA driven, accident/injury driven, and company driven. The following OSHA standards require annual training refreshers: bloodborne pathogens, confined space rescue team, hazardous waste operations and emergency response (HAZWOPER), occupational noise exposure, and respiratory protection. Toxic and hazardous chemicals all require at least initial training; the following hazardous chemicals require annual training: acrylonitrile, asbestos, benzene, butadiene, cadmium, carcinogens, coke oven emissions, ethylene oxide, formaldehyde, inorganic arsenic, lead, methylenedianiline, & vinyl chloride. First Aid/CPR requires refresher training every 2 years. Process safety management and powered industrial trucks require refresher training every 3 years. Aerial lift refresher should occur every 4 years.
Refresher training can also be required in the event of an accident, injury, or near miss. This category includes: when an operator of a vehicle or equipment is observed using it in an unsafe manner, the operator has received an evaluation that reveals the operator is not operating safely, the operator is assigned a different vehicle or equipment, or as workplace conditions change that affect safe operation of the vehicle or equipment.
Finally, the company has the ability to implement their own refresher training dates, as long as they minimally meet the OSHA standards.
Training Documentation Required
The documentation needed for training varies for each standard. But, at a minimum the following information is required. (1) Name and signature of the trainer; (2) Name of the employee (signature is not required); (3) Date of training; (4) Subject of training; (5) Proof of competency and date of evaluation. This proof of competency can be a written test, practical evaluation sheet, or a combination of both. Another critical piece of documentation is the availability of the records. The employer is required to make the training records available to employees and upon request to the Assistant Secretary and the Director for examination and copying. These training documents must be produced within 4 hours of being requested. The storage of records should be maintained for a minimum of 3 years after the date of training. Only the most current training records need to be stored. Failure to document employee safety training can lead to OSHA citations and fines in the event of an OSHA inspection or in an accident investigation.
Training resource information can also be broken into 4 categories: manufacturer, Insurance agencies, suppliers/dealers, and regulatory agencies. Manufacturers’ create manuals and other safety information that explains safe operating standards and training requirements for the equipment or machinery. OSHA relies on these manuals in the absence of written standards when writing citations. Insurance agencies can provide written training programs and even training in some cases. Equipment and tool dealers also can provide written programs and competent person training. Regulatory agencies, such as OSHA or ANSI, produces a multitude of great resources and publications. The best resources for OSHA training requirements is OSHA 2254 publication “Training Requirements in OSHA Standards.” This publication is the compilation of all OSHA standards in general industry, maritime, construction, agriculture, and federal employee programs that have training requirements.
Reposted from constructionexec.com, May 18, 2018, a publication of Associated Builders and Contractors. Copyright 2018. All rights reserved.