In all of the workplace safety inspections that I have completed in the last 30 years, I have rarely found a workplace that is meeting all of the safety training requirements of the Occupational Safety and Health Administration (OSHA).
OSHA Standards require that employees receive training so that work will be performed in a safe and healthful manner. Employees have the right to know the hazards they will be exposed to at a workplace, and OSHA requires that employers provide workplace safety training relevant to the employee’s job tasks at the employee’s initial assignment and at least annually thereafter.
What are the required training topics in the wood products and pallet industry? In order to answer this, we must first identify the required written safety programs for the industry.
There are some variances from one plant to another, and one state to another, but in general, the required written safety programs are as follows:
• Injury and Illness Prevention Program
• Bloodborne Pathogen Exposure Controls & Universal Precautions Program (For any First-Aid trained personnel)
• Confined Space Program
Control of Hazardous Energy / Lockout & Tagout
• Emergency Action Plan / Emergency Response and Preparedness Program
• Equipment Safety Training Program
• Fall Protection Program
• Fleet Safety Program
• Forklift Operational Safety Training Program (For any forklift operators)
• Hazard Communication / Globally Harmonized System Program
• Hearing Conservation Program
• Hoist and Crane Program (If you have a jib or bridge crane in operation)
• Hot Work Program (Same question, isn’t this only if there is welding done on-site? Of course, this is common for sawmills with their own blade maintenance shops.)
• Infectious Disease Program (For all employees due to COVID concerns)
• Personal Protective Equipment Program
• Personnel Lift Operational Safety Program
• Pneumatic Nailer Safety Program
• Respiratory Protection Program
• Workplace Ergonomics Program
OSHA has a great publication to assist employers on safety training requirements: https://www.osha.gov/sites/default/files/publications/osha2254.pdf
Pallet Plant and Wood Products Minimal Required Safety Training
Every single employee is required to have safety training when hired in the pallet or wood products industry. Obviously, those in administration will not need in-depth training on all subjects. For administrative, sales, and others outside of plant operations, the New Employee Safety Orientation is adequate, as long as their job tasks do not include any plant / production.
As for plant / production personnel, I recommend using the New Employee Safety Orientation, as well as the following checklist for your safety training:
Written Safety Programs
• Description and location of programs
• Relevant OSHA Standards
• Program administrator identification
• Safety Committee
• Who is in the committee, when they meet, and where the minutes are posted
• State and Federal employee poster location
• Close Call, Hazard, and Accident Reporting Procedures
• Emergency Action Plan
• Critical equipment and operations shutdown in the event of an emergency
•Emergency contact information
• Evacuation procedures; exits and egress
• Fire safety and emergencies
• Fire extinguisher locations
• Fire extinguisher operation
• First aid emergencies and first aid trained personnel
• First aid kit locations
• Emergency eyewash station location
• Hazard Communication
• Globally Harmonized System
• Safety Data Sheets
• Chemical safety
• Personal Protective Equipment (PPE)
Assignment, Maintenance, Selection, Use and Limitations.
• Safety glasses
• Safety goggles
• Hearing protection
• Other PPE related to their position may include; Hard hat, welding hood, gloves, face shield, dust masks, respirators, high visibility clothing, aprons, and special clothing
• Control of Hazardous Energy / Lockout & Tagout
• Lockout-Tagout Policies and Procedures
• Role of the Authorized Employee
• Role of the Affected Employee
• Other Employees
• Equipment Operational Safety Training
• Equipment training relevant to their position
• Hazard awareness, guarding and points of operation
• Forklift certification (Forklift operators)
• Infectious Diseases
• Exposure controls and universal precautions
• Safe lifting techniques
Please note that some positions, such as millwrights or maintenance personnel, will require even more training. This training may include: confined space, fall protection, hot work, crane and hoist operational safety or personnel lift operational safety.
Training Method
The method used in training will determine how well the employee retains what they have been taught. OSHA requires that all safety training be understandable to employees. No matter what training style or curriculum you use, each and every employee must be able to fully understand it. Obviously, if you have workers who cannot speak English, the training must be provided in a language that they will understand. And, if an employee has difficulty reading, the training must be provided in a manner other than sitting down and reading the information. I have never been impressed with a safety training presentation in which the employee just sits down and reads a pamphlet full of safety rules. When this type of training is performed, I recommend a documented evaluation testing the employee’s knowledge of the materials. I much prefer hands-on, classroom, or one-on-one instruction.
Recommended Steps for Training are:
• Show Them How You Want It Done (Always provide training materials)
• Test Them on Their Knowledge (Written, oral or practical)
• Monitor Their Operation (Supervisor observation)
• Document It (Training form)
Show Them How You Want It Done
People retain more from their training when they are physically shown what to do. This can be done through hands-on instruction, video, pictures or PowerPoint. Of course, nothing is better than hands-on learning. Training should be in-depth and specific to the equipment they will be operating. While it maybe not be required, it is always best to provide training materials along with the instruction.
Test Them on Their Knowledge
Once training has been provided, test employees on their knowledge. I prefer written evaluations, mostly because it’s the best documentation of training and knowledge you can get. There is no better proof than a written evaluation. In my experience, oral is the least effective type of evaluation, unless it’s one-on-one, but it lacks documentation. A practical evaluation is a great way to find out how well they can operate the equipment, but it too lacks documentation. And you will be monitoring their operation anyway. A written review does not have to be 10-pages in length, but it needs to be in-depth. Ten specific questions is a good number, and in those questions, you can easily test an employee’s retention. The more hazardous or technical the equipment, the longer and more in-depth the test. After the test has been completed, you should go over every question with the employee to review their answers and make any corrections.
Monitor Their Operation
After training and testing, a manager needs to monitor the trainee’s performance. Most equipment, such as: power tools, stationary machinery, or other equipment, can be evaluated as they perform their actual duties. If it’s a hazardous type of equipment, like a forklift, you can make a course, or provide them with a task to perform. The monitoring of the operation needs to be done by the instructor or a supervisor. Employee monitoring is not just a one-time deal; it should be ongoing as the employee settles into his/her job tasks.
Document It
Document, document, document. An equipment training form is the best way to document the training. Here is an easy-to-make training form that can be made to meet the needs of most training documentation. I recommend the following information be on the form:
• Employee name
• Date of training
• Type of equipment the training was conducted on
• Type of training provided
• Area for notes
• Instructor name
Then, after the training, walk the new employee around the facility to familiarize them with the components of the safety program. This practice will go a long way in embedding the information in an employee’s mind.
Editor’s Note: Jary Winstead is a safety consultant, author and trainer who serves a variety of industries including the forest products’ sector. He owns Work Safety Services LLC and can be reached at SAFEJARY@gmail.com.
New Employee Safety Orientation
Employee Name: ______________________________ Date ___/____/____
Each and every employee is encouraged to be an active part of the company’s safety program. As part of our new employee orientation and company safety program, new employees are introduced to general safety program components. This ensures that every employee will understand what to do in the event of a workplace hazard, accident or an emergency.
o Employee received the new employee orientation training. This included a review of the company’s Injury and Illness Prevention Program.
o Workplace Written Safety Programs
o Safety Program Administrator
o Control of Hazardous Energy (Affected Employee Level)
o Globally Harmonized System and Hazard Communication
As the new employee is physically walked through the workplace, check off each item as it is introduced.
o Emergency Action Plan
o First Aid Kit
o Eye Wash Station / Emergency Shower
o Fire Alarm
o Fire Extinguishers
o Emergency Exits
o Evacuation Procedures
o Hazard and Close Call Reporting Procedures
o Workplace Injury and Illness Reporting Procedures
o Safety Data Sheets
o Personal Protective Equipment
o Check if PPE is not required for position
o Safety Glasses
o Safety Goggles
o CPR Breathing Barriers
o Hearing Protection
o Dust Masks
o Gloves
o Aprons or Special Clothing
o High Visibility Clothing
o Head Protection
o Restrooms
o Drinking water
o Break and lunch area
o No smoking areas
o Hazardous areas (Equipment lanes, chemicals, Terrain hazards, etc.)
When the orientation is completed, and the listed items are reviewed, the employee and the person conducting the introduction shall sign below to verify the orientation has been completed and understood.
Employee Signature _________________ Employer Representative ____________________
