Training

Training people is a challenge. It should not be taken lightly. Your method of

information delivery makes all the difference in the world. Simply talking
about a topic is not teaching. The success of your training is not dependent on
the amount of information covered; it is dependent on the amount of
information remembered by your students.

1
 Adult Education
Help, I’ve Fallen in
pedagogy and I can’t
Get Up
Androgogy

For the purposes of this course we will define Androgogy as an adult training
methodology and pedagogy as a training methodology normally used for
teaching children.

2
Androgogy
Androgogy vs.
vs. Pedagogy
Pedagogy

•Androgogy
training adults
•Pedagogy
training children

3
 Androgogy
• 1833
introduced by German educator
• 1920
reintroduced by German social
scientist
• 1957
adopted by European educators
• 1967
introduced in U.S. by Malcolm
Knowles

If you want to dig deeper on Androgogy, there are some good books out by
Malcolm Knowles.

4
 Androgogy
Androgogy vs.vs. Pedagogy
Pedagogy
• The Child - dependent
• The Adult - independent
deep psychological need to
be self-directing
resent and resist being
forced into dependent roles
pedagological training

The child is a dependent learner who depends upon the teacher to determine
what they should learn and how they should learn it.

The adult is more independent and wants input into what they will learn and
how they will learn it.

5
 Androgogy
Androgogy vs.
vs. Pedagogy
Pedagogy
• The Child
limited reservoir of life
experiences
• The Adult
accumulated reservoir of life
experiences
resource for learning
broad base for which to relate
new learning
When the adult encounters a new piece of information, he or she compares it to
every experience they’ve had before. This determines whether the adult will
except or reject the new piece of information. Our decision-making process is
based upon our accumulated reservoir of life experiences.

The child has a limited reservoir of life experiences and so accepts new
information more readily.

6
Androgogy
Androgogy vs.vs. Pedagogy
Pedagogy
• The Child
not self-motivated
motivated by external
factors
grades
discipline
promotion

7
 Androgogy vs. Pedagogy
Pedogogy
• The Adult
motivated by need to know
don’t teach what they already know
don’t teach what don’t need to
Know
motivated by
internal factors
increased
self-esteem

8
 Androgogy vs. Pedagogy
Pedogogy
• The Child
subject-centered orientation
master content to pass
• The Adult
problem-centered
orientation
seek skills needed to apply to
real-life problems

The adult needs to feel like they have a need for the information they are
presented, or they won’t be motivated to remember it. Don’t waste an adult's
time by teaching them something they don’t need to know. If they need to
know it, then explain to them why.

9
 Pedagogy
Pedogogy
•Traditional
classroom style setting
authoritarian teacher
no input into material to
be learned
limited participation
limited group interaction

10
 Pedagogy
Teacher

Student Student Student Student Student Student

Pedagogy is rigid in form.

11
 Androgogy Trainer

Student Student

Student Student

Student Student

Androgogy is flexible and lends itself well to group training activities. The
students learn from each other through discussions and group exercises. They
learn from the trainer through participatory lecture and facilitation.

12
 Stuck in Pedagogy
FEED ME

As an analogy let’s use a banquet as our example.

In a pedagological banquet, the trainer would determine the menu, prepare the
food, determine where everybody sits, and make sure everybody cleans their
plate.

In an Androgological banquet, the trainer would lead the group as they

determine the menu. The seating arrangements would be designed for groups
of 4 to 7 people and the participants would determine where they sit.
Everyone would participate in preparing the meal and each individual would
determine what they eat and how much they eat.

13
 Education is not
the filling of a
bucket but the
lighting of a fire.

It is important to remember this. You may see it again.

14
 Androgogy
Participatory
Cooperative Effort
Interactive

The three main points of Androgogy are that everyone participates, the course
is a cooperative effort between all of the students and the trainer, and everyone
interacts with others.

15
In the classroom version of this
course we continue to teach
Androgogy by demonstrating
its use as we teach the rest of
the class. In this independent
study version we will learn
more about Androgogy by
discussing it as you study the
next section.

16
 What’s It All About
Safety, OSHA, MSHA, NIOSH,
BLS, NFPA, NASP, BCSP, ASSE,
DOT, Hazard Analysis, Citations,
Fines, Workers’ Comp,
Engineering Solutions, Liability,
Responsibility, 300, 300A, 301,
Confined Space, HAZWOPER

Is safety all about OSHA?

There’s a whole lot more to workplace safety than just OSHA. If you have
looked at safety merely as OSHA compliance, your vision is much too narrow.

17
It’s About People

18
It’s About Death

19
It’s About Agony

20
What’s It All About
What’s
Americans are at a
greater risk in the
workplace than most
workers in other
industrialized nations.

21
189
189 workers
workers die
die daily
daily from
from
WLOD
WLOD
During
During your
your 4.5
4.5 days
days inin this
this
class,
class, more
more people
people will
will die
die from
from
WLOD
WLOD than
than have
have died
died during
during
the
the past
past year
year in
in Iraq
Iraq
Almost
Almost twice
twice as
as many
many people
people
die
die WLOD
WLOD each
each year
year as
as died
died
during
during the
the average
average year
year ofof the
the
Vietnam
Vietnam War
War

22
Annually
12,
12, 285
285 WLOD
WLOD Deaths
Deaths
7,475,200
7,475,200 injuries
injuries or
or illnesses
illnesses
BLS Statistics Are Skewed
Deaths
Deaths from
from workplace
workplace illnesses
illnesses are
are not
not reported
reported in
in
BLS
BLS statistics
statistics
BLS
BLS excludes
excludes local
local government,
government, state,
state, & & federal
federal
workers
workers
Employers
Employers intentionally
intentionally under
under report
report illness
illness and
and
injury
injury
Study
Study in
in Journal
Journal of of Occupational
Occupational & & Environmental
Environmental
Medicine:
Medicine: BLS estimates missed as many
BLS estimates missed as many as as 69
69
percent
percent ofof all
all injuries
injuries

WLOD stands for Workplace Line of Duty Death.

The number of deaths in the American workplace are seriously

underreported.

23
What’s It All About
189 workers die daily:
Picture 250 children
140 spouses, and
335 parents
378 siblings
189 best friends
Total = 1292 devastated people daily, 471,580
annually
All in agony - horrible grief of a loved one who
goes to work one day and never comes home.
PTSD, other mental, economics

24
 It’s It All About This

It’s all about people, not numbers. It’s about saving lives and protecting
families from devastation.

25
A typical day in the American Workforce
165 deaths from occupational illness
5 workers die in highway vehicle
accidents
4 workers are murdered
3 workers die from falling
2 workers die in a vehicle off a
roadway
2 workers die struck by a vehicle
1 worker dies in an air, water or rail
crash

26
A typical day in the American Workforce
(continued)
1 worker dies by a falling object
1 worker is electrocuted
1 worker is killed in a fire or
explosion
1 worker dies from drowning or
toxic substance
1 worker commits suicide
1 worker dies trapped in a machine
1 worker dies under collapsing
materials

27
Even uncommon fatalities add up in the
course of a year:
30 workers die the easily avoidable death
of heatstroke
30 are poisoned to death by carbon
monoxide gas
10 die from exploding tires
12 farmers are gored or trampled to
death
8 workers inspecting or cleaning
machinery are burned to death by
escaping steam

28
 Getting to the Heart of Safety

Every Statistic Represents A

Once Beating Heart and A
Number Of Broken Hearts

29
 Most Important Safety
Manager/Trainer Qualification

It’s Not a Job, it’s a

Way of LIFE!!!

Being a safety trainer is not your typical nine-to-five job. It requires a

dedication much greater than the average job. It requires a genuine concern for
your fellow man that transcends other concerns in your life. It means going the
extra mile to assist employees in need of help. It requires sacrifice and a great
deal of dedication.

30
 Three Types of
Trainers

From our perspective there are basically three types of trainers.

31
 Three Types of Trainers
Facilitator
encourager
motivator
coach
Participatory Lecturer
Non- Participatory
Lecturer
information dumping

The facilitator maintains a very loose control of the classroom. He simply tries
to keep the class on a reasonable track and timeline. Facilitation is an excellent
way to teach, but it doesn’t lend itself well to technical topics like safety. The
true facilitator isn’t really looking for right or wrong answers instead they let
the group determine their own answers. Unfortunately when it comes to safety
there often are right and wrong answers. Use facilitation to whatever extent
you can effectively. Group projects with appropriate input from the trainer is a
form of controlled facilitation that will work well for you.

Participatory lecture means the trainer presents information, but causes a great
deal of interaction with the students. The participatory lecturer will often ask
questions of the students and use other measures to encourage their
participation. This form of training works quite well.

The non-participatory lecturer presents information but discourages feedback

from students. This is often accomplished by failing to encourage questions
and comments or reacting negatively to questions and comments. This form of
training is very ineffective.

32
Facilitation Example Using:

Who is OSHA?

In the classroom version of this course, we use the question “Who

Is OSHA” to begin our discussion of OSHA. We throw the
question to the audience and let the discussion run its course with
the students and within their various groups. This exemplifies
facilitation for them. Unfortunately we can’t do that here.

33
 Participatory Lecture Example
Using:
OSHA General Duty Clause 5(a)
OSHA Mission
– General Duty
Clause

To exemplify participatory lecture we explain OSHA’s general

duty clause as an explanation of OSHA’s mission, and do so by
ensuring class participation.

34
General
General Duty
Duty Clause
Clause
1.
1. What
What does
does itit say
say in
in simple
simple terms?
terms?
5(a)(1) - "Each employer shall
furnish to each of his or her
employees employment which
is free from recognized hazards
that are causing or are likely to
cause death or serious physical
harm to his employees"

35
 General Duty Clause
5(a)(1) - The
employer must
provide workers
safety from
recognized hazards
likely to injure them.
This is a plain English explanation of what the first part of the general duty
clause says.

36
How
How does
does the
the General
General Duty
Duty Clause
Clause
expand
expand OSHA
OSHA’s ’s authority
authority beyond
beyond
enforcing
enforcing specific
specific OSHA
OSHA regulations?
regulations?
Employers required to
protect employees
even if a specific standard
does not exist or
if some hazard still exists after a
standard is complied with

The general duty clause is found in OSHA’s enabling legislation.

It was initially intended merely as an explanation of why OSHA
was being created. But since it’s a law, OSHA enforces it as such.
This allows OSHA to write citations for hazards for which no
specific standard exists. It also allows OSHA to site hazards that
still exist after the appropriate standard has been applied.

37
Employer
Employer Requirements
Requirements
Employee Safety vs. OSHA
Compliance
OSHA Compliance = a Safe
Workplace?

If you comply with every OSHA regulation does that guarantee

you will have a safe workplace? Of course not. There is not a
specific OSHA regulation for every hazard that might exist.
OSHA standards are designed to be minimum standards so there
may be hazards that are beyond the coverage of OSHA
regulations. True workplace safety means considering all hazards
whether OSHA covers them or not.

Does OSHA compliance equal a safe workplace? The answer is

no. We must exceed mere OSHA compliance in order to truly
protect our workers.

38
 What
What does
does the
the the
the General
General Duty
Duty
Clause
Clause reveal
reveal about
about OSHA
OSHA’s ’s
perspective?
perspective?
5(a)(1) - "Each employer shall
furnish to each of his or her
employees employment which
is free from recognized hazards
that are causing or are likely to
cause death or serious physical
harm to his employees"
Since this is OSHA’s enabling legislation, it tells us something about OSHA’s
perspective of workplace safety. OSHA’s mandate is to protect employees and
to enforce safety requirements upon employers. OSHA was created for the
benefit of employees.

39
OSHA General Duty Clause 5(b)
OSHA Mission
–General Duty
Clause

40
 General
General Duty
Duty Clause
Clause
5(b) Each employee shall
comply with occupational
safety and health standards
and all rules, regulations,
and orders issued pursuant
to this Act which are
applicable to his own actions
and conduct.
5 (a) is only half of the general duty clause. 5 (b) is the other half. 5 (b)
requires employees to obey all safety rules. It is interesting to note that this is a
federal law that requires employees to follow your safety plans, programs,
policies, and procedures. This makes firing an employee for excessive safety
violations much easier because you’re firing them for disobeying a federal
law.

41
Employee
Employee Requirements
Requirements
Employees are required
to follow all safety rules
regulations etc.....
Employee dismissal

42
 Employee misconduct
defense.
- 2 requirements

OSHA recognizes that some injuries are the fault of the worker. You may still
receive a citation from OSHA but you have the right to what is called “The
Employee Misconduct Defense”. The employee misconduct defense requires
that you be able to prove two things at the OSHA hearing.

First, you must be able to show that you have done everything required by
OSHA in the area in question that is required by OSHA. For example, if the
employee was killed or injured because he or she was not wearing proper PPE
then you must be able to prove that you have done your PPE hazard analysis,
that you have properly fit tested equipment, that you have properly supplied
required equipment, and that you have properly trained your employees in its
use.

Secondly, you must be able to prove that you use progressive discipline to
enforce your safety programs, policies, and procedures.

43
Defining Workplace Safety.
Now we’ll discuss 3 very
different perspectives of
Workplace Safety.

The 3 Safety Paradigms.

44
The First Paradigm

Regulatory Compliance

45
 Example – Participatory Lecture
Regulatory Compliance
Often Seen Only as OSHA Compliance
Other regulatory agencies
OSHA Compliance = Workplace Safety?
Objectives:
Avoid Citations
Web Search Using “Workplace Safety”
Most sites will be about regulatory compliance
Focus on compliance restricts our
vision

If we see only OSHA compliance as safety then we have tunnel

vision. Many employers have this type of tunnel vision. If OSHA
inspects them and doesn’t write any citations they think that
means they’re safe. Regulatory compliance is only a part of our
overall safety program.

46
The Second
Paradigm
“The Business of
Safety”

47
 Examp
Financial Concerns le – P arti cipa tory
Lec tu
The Business of Safety re
Accidents = money = business
“We were not hired because our companies were
altruistic about providing an environment where
employees did not get hurt. We were not hired
because our companies were enamored with
safety. However, we were hired because it makes
good business sense. We were hired to reduce the
costs of workers' compensation, the medical costs
resulting from injuries, and the costs of potential
OSHA citations.”
To cover the cost of a $500 accident, employer
would have to:
Sell 61,000 cans of soda
Sell 253,000 donuts
The maximum value a human life = $1.54 million

It is true that it is cheaper to maintain a safe workplace than to pay

the price for injuries and deaths. It is an important point that may
help you tremendously in budget requests. But it cannot be our
primary paradigm for safety. That would mean putting a monetary
value on human life and limb.

48
 The Third
Paradigm
Ethics/Morals/
Humanitarian Concerns

The true paradigm for workplace safety is ethics. It is simply doing the right
thing to make your employees safe. It doesn’t concern money or OSHA nearly
as much as it concerns people. It’s all about people.

49
Which Perspective is Correct?
1) Regulatory
1) Regulatory Compliance
Compliance
2) Financial Concerns
2) Concerns
3) Ethics/Morals/Humanitarian
3) Ethics/Morals/Humanitarian
The
The objective
objective is is not
not regulatory
regulatory
compliance,
compliance, and and itit is
is not
not saving
saving
money,
money, itit is
is the
the avoidance
avoidance of of
human
human injury.
injury.

50
 Eight Principles of a Safe Workplace
1. Safety is an Ethical Responsibility. At
its core, ethics holds up a positive vision of
what is right and what is good. It defines what is
"worth" pursuing as guidance for our decisions
and actions. Workplace injuries and deaths are
too often seen in the abstract as statistics. But
when it happens to someone we love, we
suddenly see the reality of the horrible pain and
suffering and its widespread effect. It is our
ethical responsibility to do what is necessary to
protect employees from death, injury, and
illness in the workplace. This is the only
foundation upon which a true safety culture can
be established in any workplace.

51
 Eight Principles of a Safe Workplace

2. Safety is a Culture Not a Program. The

combined commitment and participation of
the entire organization is necessary to
create and maintain an effective safety
culture. Every person in the organization,
from the top management of the
corporation to the newest employee, is
responsible and accountable for
preventing injuries.

52
 Eight Principles of a Safe Workplace
3. Management is Responsible.
Management's responsibility is to lead the
safety effort in a sustained and consistent
way, establishing safety goals, demanding
accountability for safety performance, and
providing the resources necessary for a
safe workplace. Managing safety is the
responsibility of every supervisor, from the
first line supervisor to the Chairman of the
Board.

53
 Eight Principles of a Safe Workplace

4. Employees Must Be Trained to

Work Safely. Awareness of safety does
not come naturally; we all need to be
trained to work safely. Effective training
programs both teach and motivate
employees to be a productive part of the
safety culture.

54
 Eight Principles of a Safe Workplace
5. Safety is a Condition of
Employment. The employer must exhaust
every reasonable means to lead, motivate,
train, and provision employees to maintain a
safe workplace. But, in the event the employee
refuses to take the actions required to work
safely, the employer must utilize a system of
progressive discipline to enforce safety
requirements and ensure the cooperation of the
employee or the removal of the employee from
the workplace in order to protect the employee
and their coworkers.

55
 Eight Principles of a Safe Workplace
6. All Injuries Are Preventable.
Sometimes accidents occur without the
apparent indication of fault or blame. But
there is always some chain of events that
occurred leading up to the accident that,
had we realized the eventual outcome,
someone could have interceded. The
fundamental belief that injuries are, by
their nature, preventable is a catalyst that
encourages us to prevent injuries.

56
 Eight Principles of a Safe Workplace
7. Safety Programs Must Be Site Specific with
Recurring Audits of the Workplace and Prompt
Corrective Action. The purpose of the workplace
audit is to discover and remedy the actual hazards of
the site before they can injure workers. Recurring
hazard analyses, comprehensive inspections, and
aggressive investigation of accidents or near misses,
discover potential workplace hazards and identify
weaknesses in safety plans, programs, policies, and
procedures. Safety regulations and generic safety
programs are not sufficient means to discover hazards
because they are not specific to the individual
workplace. A safety audit program is site specific.
Whenever a safety deficiency is found, prompt action
is required both to overcome the hazard and to
reinforce the message that safety is a priority.
priority

57
 Eight Principles of a Safe Workplace

8. Safety is Good Business. Reducing

workplace injuries and illnesses reduces
the costs of workers' compensation,
medical expenses, potential government
fines, and the expenses of litigation.
Effective workplace safety is not an
expense, its an asset.

58
 NASP ISM Program
Based on the preceding principles
and philosophy
• System by which the safety culture
is developed
Thorough safety audit of your
facility
• A site specific Safety Culture
System is created and implemented
Behavior Based Safety
Behavior based safety works well with the paradigm of ethical performance.

59
A Safety Manager is not a Safety
Program
A Safety Program requires the ““buy
buy in”
in”
of every affected person
The Safety Program is the Safety
Culture You Create in Your
Workplace
The Safety Culture Involves Every
Person in the Workplace Doing their Part
Your Job is to Teach Them Their Roles
and Manage Their Performance

60
The Safety Culture Involves Every Person
in the Workplace Doing their Part
- like an Orhcestra
Your Job is to Teach Them Their Roles
and Manage Their Performance
- Like a Conductor

61
Safety Trainer
Qualifications

62
 Instructor
Instructor Qualifications
Qualifications

OSHA
ANSI
The Courts
Your Own

Qualifications for safety trainers can be viewed from several different

perspectives. Here we’ll talk about how safety trainer qualifications are
effected by OSHA, ANSI, The Courts, and your own requirements.

63
 OSHA’s Instructor Qualifications
OSHA’s
We can
We can break
break this
this paragraph
paragraph down
down into
into the
the
following elements:
following elements:
1)
1) Instructors should
Instructors should be
be deemed
deemed competent
competent
2)
2) Previous documented
Previous documented experience
experience in in their
their area
area of
of
instruction
instruction
3)
3) Successful completion
Successful completion ofof aa "train-the-trainer"
"train-
"train-the-
the-trainer"
program
program
4)
4) Training in
Training in their
their area
area of
of instruction
instruction
5)
5) An evaluation
An evaluation of
of instructional
instructional competence
competence by by the
the
Training Director
Training Director
6)
6) Maintain professional
Maintain professional competency
competency by by participating
participating in:
in:
a)
a) continuing education
continuing education
b)
b) professional development
professional development programs
programs
c)
c) completing successfully an annual refresher
completing successfully an annual refresher course
course
d)
d) having an
having an annual
annual review
review by
by the
the Training
Training Director
Director

From 1910.120 appendix E.

64
Professional Qualifications for
the Courts
Qualify as a Professional
(Expert) Witness for each
class taught
Civil or Criminal Trials
Opposition will bring in an expert
witness
• That witness will testify that you were
wrong
• Your testimony vs. Their Testimony
• If they are an ““expert”
expert” and you are not?

65
 Qualifying as
Qualifying as aa Professional
Professional
Witness Before the Courts
 Based on
Based on Federal
Federal Rule
Rule of
of Evidence
Evidence 702
702
"if scientific,
"if scientific, technical
technical or
or other
other specialized
specialized
knowledge will
knowledge will assist
assist the
the trier
trier of
of fact...a
fact...a witness
witness
qualified as an expert...may testify thereto
qualified as an expert...may testify thereto in in the
the
form of an opinion.“
opinion.
form of an opinion.“ “
Determined by
Determined by judge
judge
 Guidelines For
Guidelines For The
The Expert
Expert Witness,
Witness, Judge
Judge
Timothy T. Daley
Timothy T. Daley
“Specific education,
“Specific education, training,
training, related
related experience
experience
and current knowledge are essential ingredients
and current knowledge are essential ingredients to to
being certified as an expert witness.
being certified as an expert witness.
Precise validation,
Precise validation, available
available to
to the
the court
court before
before
attendance, may
attendance, may lead
lead to
to the
the uncontested
uncontested
declaration of
declaration of the
the witness
witness asas an
an expert."
expert."

You should try to be able to qualify as a professional witness on every topic

that you teach. This is not a requirement but rather something to aspire to.

66
 Instructor
Instructor Qualifications
Qualifications
ANSI
Subject matter expertise and training
delivery skills
Appropriate level of technical knowledge,
skills, or abilities in the subjects they teach
Competent in techniques and methods
appropriate to adult learning
Continuing education, development
programs, or experience related to their
subject matter expertise & delivery skills
Apply adult learning principles appropriate to
the target audience

67
Documentation of Qualifications
 Credibility of Documentation
Third party objective validation
 National Association of Safety Professionals
Board of Registration and Certification
Based Upon OSHA Recommendations/Requirements and
the Requirements of the Courts for Expert Witness
Other certifications and registrations are based on the entire field
field of
safety or even safety and the environment combined and require a
college degree or many years of experience and training.
NASP certifications and registrations are validated in the same way
OSHA and the courts consider one's qualifications, subject by subject.
subject.
•• This subject
This subject by
by subject
subject validation
validation allows
allows NASP
NASP members
members to
to demonstrate
demonstrate
demonstrate to
to
the courts,
the courts, regulators,
regulators, employers,
employers, and
and potential
potential employers
employers their
their precise
precise
knowledge, skills,
knowledge, skills, and
and abilities.
abilities.

68
 NASP Certifications
Topical Certifications - On Website
Professional Certifications + others
SAC (Certified Safety Auditor)
STS (Safety Training
Specialist) CSM (Certified Safety Manager)

PST (Professional Safety CSC (Certified Safety

Trainer) Consultant)

MST (Master Safety Trainer) CSA (Certified Safety

SPS (Safety Planning Administrator)

Specialist) MSA (Master Safety

Administrator)
EHS (Certified Environmental
Health and Safety LSP (Licensed Safety
Management Specialist) Professional

69
We’ve discussed 3 Types of Training
Facilitation
Participatory Lecture
Information Dumping
We’ve discussed 3 Perspectives of
Workplace Safety:
Regulatory Compliance
Monetary Incentive
Ethics
We’ve discussed Trainer Qualifications.
Now We’ll talk about the people we deal
with

70
Take the bad with the
good
Win them all over
Win Over the:

71
The Happy Employee

72
The Greedy Employee

73
The Joker

74
The Leader

75
The Loud Mouth

76
The Busy Body

77
The Disgruntled Employee

78
The Information Specialist

79
Keeper of the Nuts

80
The New Guy

81
The Expert

82
The Supervisor

83
The Mole

84
The Frustrated Employee

85
Da BOSS !!!!

86
Da Boss
Boss’’ Wife

87
The Boss
Boss’’ Kid

88
 The People You
Have to Deal With
–
Students

89
Handling Problem
Students
While Keeping
Your Cool

90
 EACH OF US
BRIGHTENS A ROOM
☺ SOME WHEN WE
COME IN

☺ SOME WHEN WE
LEAVE

91
 Objectives
Objectives
Don’t Embarrass
Keep Your Cool
“just because someone pulls your chain
doesn’t mean you have to flush”
Put Good of the Class First
• Disruptions out
Control without Alienation
if possible
Don’t Lose Control of Class
Subtle Tactics at First

Of course you want to be nice and you want your students to like you.
However, you have to be careful to maintain control of the classroom.
While your touch should be light, the students must know that you are in
control. When someone is causing a disruption try to handle it subtly without
embarrassing the person. If that doesn’t work, however, you have to put the
good of the whole class first. If a student is distracting the class from the
material being presented, then they are taking from every student and you
must put a stop to it. It’s subtle tactics don’t work, then call for a break in class
and talk to the offending party openly and honestly. If necessary, tell them they
will have to stop their disruption or leave the classroom. If necessary, do not
hesitate to kick someone out of class.

92
 Control Tactics
1. Make Eye Contact
2. Move Toward Them
3. Ask Question
4. Check Watch
5. Talk During Break
6. Dismiss

93
Types of
Problem
Students

94
 Side
Side Conversations
Conversations
Distracts Students
Distracts Instructor
May Be Subject
Related
May Be Personal

In a pedogological training class, side conversations are always considered bad.

We’ve all heard the instructors say “would you like to share that with the
class” or “the action is up here.” In Androgological training, we must
recognize that the side conversation may very well be a discussion of the topic
you’re currently teaching. A side conversation is not necessarily bad; it’s only
bad when it distracts other students. Simply asking one of the to a question that
you know they can answer will stop the problem without embarrassment.

95
 Clash
Clash Between
Between Students
Students
May Divide Class
May Escalate

A clash between students is the most volatile of all problem student situations.
A verbal disagreement can very quickly become physical. It is of utmost
importance to act quickly to quell such a clash. This is one case where it is
difficult to act subtly. It is much more likely that you will have to react openly
and call those involved down in front of the class. This will embarrass them
and possibly add to their ill feelings. The best way to handle a clash between
students is to pretend like it’s time for a break and send the class on break
while you talk to the two individuals involved. When you talk to these
individuals, tell them in a very straightforward fashion that their actions will
not be tolerated and they will be kicked out of class if they continue. If there is
any indication that this is not going to work, then kick one or both out of the
class.

If you let such a clash continue it often will divide the class and you will have
a very difficult time regaining control of the class.

96
 Challenger \Obstinate\ Angry
Challenger\Obstinate\
Recognition Seeker?
Distaste for Authority
Argumentative
Critical
Divisive
Resentful Responses
The student who constantly challenges you, is obstinate, or is angry is
sometimes very difficult to deal with. You must first check your own emotions
and show no sign of anger. We can’t help what we feel, but we can help what
we show. The way to handle this person is to talk to him during a break in
class and tell him exactly how you feel about what he’s doing. You will often
learn that he is not angry at you, but is instead angry at a supervisor, a
coworker, or family member. Whether it’s you that he is mad at or not,
you must make it very clear to him that his disruptive actions must cease
completely or he will be kicked out of the class.

97
 Overly
Overly Talkative \Rambler
Talkative\Rambler
Easily Gets Off Subject
Uses Analogies That
Aren’t Relevant
Misunderstands
May be Seeking
Recognition

This person gives you a problem maintaining your timeline. As an

Androgological trainer, we go to great effort to encourage students to speak up
so we need to be careful how we handle one that talks too much. Don’t do
anything that would make the rest of the students hesitant to speak up. Subtle
ways to deal with this type of person include giving him or her the recognition
they are looking for. Use them as a type of assistance to pass out papers for
you, keep the score during games, and other things that put them in the
limelight.

If nothing else works, then you must talk to them during a break and explain
to them that so much input from them is keeping others from having the
opportunity to speak and is wreaking havoc with your timeline.

98
 Definitely
Definitely Wrong
Wrong
Wrong Answer
Inappropriate
Analogy

When a person gives an answer or makes a point that is obviously wrong,

handle them with care. Remember, you don’t want to embarrass them.
Sometimes you can find something in their statement that is true and lock on
to that. But we can’t let the other students in the class believe that some safety
point is correct when it is actually wrong.

99
 The Dominator
Super SME
Has a story/
example/
regulation
for everything
Usually feels
being helpful
Discourages other
students from participating
The dominator either knows or thinks he knows a lot about the subject.
You can use different measures to try to take the conversation from him to
other students in the class, such as asking a question of another student.
If you cannot handle him subtly, then talk to him during a break.

100
 The Mute
Speaks only
when spoken to
Often shy
Often stifled by
the Dominator
Won
Won’t’t compete
for the floor
Often pays close attention
Often intelligent
The shy person that just won’t speak up is a particular problem in a class
where you’re dependent upon student input for participatory lecture. Ask this
person frequent questions, but be absolutely sure they are questions that he or
she can answer.

101
Applying the
Principles of
Participatory
Learning

102
Applying the Principles of
Participatory Learning
Case Studies Role Playing
Instruments Film/Video
Games Learn by Doing
Puzzles Ice Breakers
Reverse Points Exercises

103
 Other Participatory
Learning Activities

The key is
Variety

No matter how good one technique works for you the students will grow tired of it
if you overuse it.

104
 Communication

Speaking Effectively
Listening Effectively

I always ask the question here “which is more important, speaking effectively
or listening effectively?” After some discussion, the groups always come to the
conclusion that they are equally important for an Androgological trainer. He
must listen effectively to gauge the interest of the group and the effectiveness
of your training. Speaking effectively is important in being sure that you are
communicating what you intend to communicate.

105
 Effective
Effective Communications
Communications
Semantics
Definitions
Absolutes
always/never
Statistics
Inflexibility
Reality Based
Preparation Credibility
Teaching Style
Course Materials
Each of these indicates a potential trap for the Androgological trainer. We will
talk about each of them.

106
 Semantics

Frame of Reference

The way in which your students understand what you are saying is dependent
upon their frame of reference.

107
 Semantics
Frame of
Reference
Running
Politician
Athlete
If you’re talking to politicians, running is going to indicate running for office.
If you’re talking to athletes, running is going to indicate running around the
track.

108
 Semantics
Frame of
Reference
Right
In Class
Driving
In the classroom “Right” would indicate correct, while driving right would
indicate the opposite of left.

109
 Frame
of
Reference
OSHA
Good?
Bad?

Whether your students think that OSHA is good or bad will depend upon their
frame of reference. Those who have had good experiences with OSHA will
say they’re good. Those who have had bad experiences with OSHA will say
they are bad.

110
 Semantics
Clarify
Restate in varying
ways
Question
Examples

In speaking to your class, keep these things in mind. Your frame of reference
might differ from your students, so in some cases they may hear something
very different than what you intended. In order to avoid this, try restating
important points in varying ways, asking frequent questions of the students,
and using plenty of examples.

111
 Semantics
Beware
“Push Button Words”
Your Body Language
Voice Inflexion

Beware of push-button words. Push-button words may be different for different

people. Especially avoid words that could indicate racial or sexual descriptors.
I once said to a class “okay guys let’s take a break." I later had a woman come
to me and say “I am not a guy, I am a girl." From my frame of reference the
word “guy” means everyone not just men. Obviously her frame of reference
was different.

112
 Effective
Effective Communications
Communications
Semantics
Definitions
Absolutes
always/never
Inflexibility
Preparation
Teaching Style Credibility
Course Materials

Speaking in absolutes such as always or never.

113
 Avoid Absolutes
“The length and specificity
of one’s answers is
inversely proportionate to
his/her intelligence level.”
Marilyn Vos Savant

This quote makes the point quite well that being too specific in our answers
can often be wrong. There are few things in life that are always or never. If
you present some point as always or never and a student comes up with an
exception, your credibility will be damaged.

114
 Effective
Effective Communications
Communications
Semantics
Definitions
Absolutes
always/never
Inflexibility
Preparation
Teaching Style Credibility
Course Materials

Being inflexible, or to say it a little more rudely, being hardheaded, can also
damage your credibility. I use terms like “almost always”, “in the vast
majority of cases”, or “the vast majority of the time” instead of speaking in
absolutes. Then when I have a point that truly is an absolute it is very
influential.

115
 Inflexibility

Inflexibility
Reality Based

When you’re teaching blue-collar workers, they see their world (or their frame
of reference) as the real world. If you speak over their heads or if you fail to
consider the problems they encounter in their work they will see you as being
from the ivory tower. They will then discount most of what you say.

116
 Effective
Effective Communications
Communications
Semantics
Definitions
Absolutes
always/never
Inflexibility
Preparation
Teaching Style Credibility
Course Materials

Preparation of class. The Androgological teaching style is one of high-energy

and an enjoyable atmosphere.

117
 Preparation
Teaching Style
Androgogy
Indicates care for the students’
comfort, enjoyment, and effective
learning
Course Materials
Indicates level of effort you put
forth for sake of students

It is considerably harder to prepare a course to be taught Androgologically

than to prepare a lecture. Many students will realize this and be appreciative of
the time that you have put into making the class enjoyable for them.

The same thing goes for the course materials. If they are sloppy, the students
will feel that you don’t see the class as very important.

118
Characteristics
of an Effective
Trainer

119
An Effective Trainer
Make Eye Contact
Be Friendly
Be Understanding
Be Patient
Be Honest
Adjust to the Audience
Maintain Control

120
 An Effective Trainer
Self Presentation
Energy
Happy
Self-Confident
Serious about safety

Your self-presentation greatly influences your students. If you are enthusiastic

they will be enthusiastic. If you are energized and happy, it will wear off on
your students. If you are self-confident they will have confidence in you. If
you are not serious about your topic your class will be a total flop. I once heard
a trainer open his class with “I don’t want to be here anymore than you do”.
He destroyed his class with that one comment.

121
 Reverse Points
Exercise
How to demotivate a
student
How to lose credibility
How to increase
accident/injury rate by your
teaching
how to lose control
how to train pedogologicaly

A reverse points exercises is simply taking an important point and reversing it.
For example a trainer who knew his students had grown tired of reading and
discussing SDSs every year decided to use a reverse points exercise. As in all
Androgological classes, he had his class divided into small groups. He then
gave each group an SDS and told them to come up with as many ways as
possible to mishandle the chemical killing and injuring the most people.

Naturally each group simply took the safe handling methods and reversed
them. The students learned the proper way of handling the chemicals but they
did so in a fun way. The groups competed against each other to see who could
come up with the most items.

122
 Plans, Programs,
Policies, Procedures
Why?

Your plans, programs, policies, and procedures should be step-by-step

procedures for your employees to follow in order to safely perform a task.
Some people merely restate the OSHA regulation for a plan or program and
call that their plan or program. It is not. OSHA regulations explain many plans
and program requirements, but they are generic so that they apply to everyone.
You have to take those requirements and make them site-specific. When you
learn from an OSHA regulation that entering a confined space requires certain
safeguards it is not sufficient to simply say that and call it a plan. Instead, you
must write step-by-step procedures specific to your confined spaces that tell
your employees exactly how to safely enter the space.

Just because OSHA doesn’t require a certain plan or program does not mean
that you shouldn’t have one. If your employees perform a task that could cause
harm to themselves or others, you should write safe procedures for that
task whether OSHA requires it or not.

123
 Why Have A Safety
Program?
It’s the Right Thing to
do.
What other reasons are
there?

Why do we need to have a safety program? We see safety as an

ethical responsibility. Designing an all-encompassing safety
program is simply the right thing to do. But there are other
reasons to develop a true and effective safety program.

124
 Why Comply?
Employee Safety
Civil Liability
Criminal Liability
Regulatory Compliance
Personnel Morale
Insurance

These are the primary reasons for having a safety program. They
are in priority order as I see it. It’s okay if you think the priority
order should be different.

125
 Why
Why Comply?
Comply?

Employee Safety
Civil Liability
Criminal Liability
Regulatory Compliance
Personnel Morale
Insurance

The first reason is, of course, Employee Safety. Keeping employees

safe whether or not some regulation says we have to is simply the
right thing to do, and is the primary reason for having safety
programs.

126
 Employee Safety
Annually
12, 285 WLOD Deaths
7,475,200 injuries or
illnesses

127
Nearly 60 workers are injured
or made ill every minute of
the work week (based on 40 hrs/week)
Consider the Pain and Suffering:
• disfigurement
• psychological damage

Over 189 workers die on the

job each day (based on 40 hrs/week)
Consider the Pain and Suffering:
• pain of death itself
• anguish of spouse, children, family, friends
• psychological damage to those left behind

128
 Statistics
Most likely killers in the workplace
•• BLS
BLS –– Based
Based on
on Average
Average 1996
1996 -- 2000
2000

CORRECT STATS

According to the Bureau of Labor Statistics the five year period from 1996 to
2000 resulted in deaths in the workplace in the following order

129
 #1 ?

The number one killer in the workplace --

130
 Transportation
Accidents
Includes:
Highway
Non-Highway
Air
Water
Rail

Was transportation accidents. This included all types of work-related travel.

131
 #2 ?

The number two killer in the workplace --

132
 Workplace Violence
robberies/crimes - 71%
work associates - 11%
police - 8%
security guards - 6%
personal acquaintance - 4%

Was workplace violence. More people died as a result of murder at work than
from any other work-related incident except transportation. It’s a sad
commentary on our society.

133
 #3 ?

The number three killer in the workplace --

134
 Falls
fall to lower level - 89%
fall on same level - 8%
unspecified - 3%

Falls. They’re divided into two categories -- Falls to a lower level and falls on
the same level.

135
 #4 ?

The number four killer in the workplace --

136
 Struck by Objects
most struck by falling
object
Note: A subcategory of BLS “Contact
with Objects and Equipment”

Struck by objects.

137
 #5 ?

The number five killer in the workplace --

138
 Entrapment in Equipment

Note: A subcategory of BLS “Contact with Objects

and Equipment”

Entrapment in Equipment.

139
 #6 ?

The number six killer in the workplace --

140
 Electrocutions

Note: A subcategory of BLS “Exposure

to harmful substances or environments ”

Electrocutions

141
 #7 ?

The number seven killer in the workplace --

142
 Fires and Explosions

Fires and Explosions

143
 #8 ?

The number eight killer in the workplace --

144
 Chemicals/hazardous
atmospheres

Note: A subcategory of BLS “Exposure

to harmful substances or environments ”

Chemicals and Hazardous Atmospheres

145
 Employee
Employee Deaths
Deaths &&
Injuries
Injuries BBS
BBS 55 Year
Year
1) Transportation Accidents
2) Workplace Violence
3) Falls
4) Struck by Objects
5) Entrapment in Equipment
6) Electrocutions
7) Fires and Explosions Video Clip

8) Chemicals/hazardous
atmospheres

146
 Why
Why Comply?
Comply?

Employee Safety
Civil Liability
Criminal Liability
Regulatory Compliance
Personnel Morale
Insurance

Another reason for having a safety program is protection from

civil liability. These days you expect a lawsuit when almost
anything goes wrong. The Great American Dream seems to be
“sue someone and get rich." Worker’s Compensation laws help
limit lawsuits, but they still occur often. Losing such a suit can
devastate a company financially.

147
 Civil Liability
For Trainers
Normally Based
on “Failure to
Warn”

Most lawsuits are based on a failure to warn. That’s why you have
so many warning stickers on the goods that you buy. When it
comes to workplace safety the safety trainer is the primary
“warner”. You can help protect yourself and your company from
civil liability by being sure that your training is thorough and
complete.

148
 Civil Liability

Professional Liability
Personal Liability

There are two types of civil liability. Professional liability is when

your company is sued and/or you are sued for acting on behalf of
the company. If you lose this type of suit, the company pays the
award and the company pays for the attorneys.

Personal liability is when you are sued individually and not as an

agent for the company. Judges seldom allow these types of suits
but they do happen.

149
 Civil Liability
Williston vs. Andrews,
H Tech, Inc. et al
compressed air hose case
precedent for personal
liability - Horseplay
peer, supervisor, employer
all successfully sued

150
 Civil Liability
Register vs. Howard,
Foxworthy, Industrial
Clean, Inc.
fire in rail car from solvent
precedent for personal and
professional liability
supervisors, employer all
successfully sued

In this precedent-setting case, the judge allowed personal suits to

stand because the action was so egregious. The supervisor did not
perform due diligence in determining the hazards of the chemical
that he instructed the workers to use inside of a rail car. A simple
check of an SDS would have shown the material to be quite
flammable and unsuited for the intended use.

151
 Why
Why Comply?
Comply?

Employee Safety
Civil Liability
Criminal Liability
Regulatory Compliance
Personnel Morale
Insurance

Criminal liability is a much greater concern than many people

realize. People can and do go to jail for safety violations. Most of
the time, the charge is not a direct violation of an OSHA regulation
but is the violation of a state law prompted by the failure to adhere
to an OSHA regulation. An example is charging a manager or
supervisor with a state murder charge when someone was killed in
the workplace.

152
 Criminal Liability
Hamlet Fire
employer locked exit doors to
control stealing
27 employees died in a fire
owner, plant manager, director of
operations charged with
involuntary manslaughter
owner was sentenced to 19 years 11
months

153
 Criminal Liability
Illinois vs. Film Recovery
Systems
removing silver from photo film
untrained and no PPE
died from acute cyanide poisoning
charged owner and foreman with
murder
25 years in prison

154
 Why
Why Comply?
Comply?

Employee Safety
Civil Liability
Criminal Liability
Regulatory Compliance
Personnel Morale
Insurance

155
 Regulatory
Regulatory Compliance
Compliance
Satisfying
OSHA and MSHA and
NIOSH and NFPA and
CONGRESS and Unions
and Big Business, etc.

We’ve already discussed regulatory compliance enough. I hope we agree by

this point that regulatory compliance is not our number one priority.

What about the effects of an unsafe workplace on personnel morale?

156
 Why
Why Comply?
Comply?

Employee Safety
Civil Liability
Criminal Liability
Regulatory Compliance
Personnel Morale
Insurance

157
 Personnel Morale
Maslow
Safety Needs

A human being's need to feel safe is one of our most basic needs. No matter
how many perks an employee receives, they will not be happy if they think
they are unsafe.

158
 Why
Why Have
Have A
A Safety
Safety Program?
Program?

Employee Safety
Civil Liability
Criminal Liability
Regulatory Compliance
Personnel Morale
Insurance

Because of the insurance savings, it is much cheaper to have a safe

workplace than it is to have an unsafe workplace.

159
 Insurance

Workmen’s Comp.
Proven Effectiveness

Worker's compensation rates are based upon the history of injuries in your
workplace. If you lower your injury and illness rate and maintain that lower
rate, you will experience lower premiums.

160
 Providing a Safe Workplace
Where Do You Start?
With OSHA Regulations?
With reducing insurance
costs?
With determining what
may hurt your employees?

Obviously we are going to begin with determining what may hurt our
employees.

161
Determining What May Harm
Your Employees
Safety Audit
Purpose
to discover circumstances,
situations, equipment, or materials
that may harm a person
There is no more important skill to
the safety professional than the
ability to discover and remedy
hazards before they can injure
workers

162
 3 Tools of the Safety Auditor
Hazard Analysis
Inspections
Accident/Incident
Investigation
Rather than an auditor in the sense of a
financial auditor, consider yourself an
investigator in the sense of a detective
who is carefully searching for clues that
indicate potential injury scenarios.

163
 Tools: Hazard Analysis, Inspections, Investigations

Job Hazard Analysis

• Or JSA
Change Analysis
• Change of process, equipment etc.
Process Hazard Analysis
• series of actions/operations that convert
raw material into a product
Phase Hazard Analysis
• an operation involving a rapidly
changing work environment, different
contractors, and/or widely different
operations – common to construction

If you haven’t already taken the NASP Certified Safety Auditor Course, we
suggest that you take it. This discussion of safety audits is merely a review.

The first tool on our list is hazard analysis. As you can see there are four
different types of hazard analysis. The job hazard analysis, or job safety
analysis, breaks the job down into specific tasks and analyzes the safety needs
in performing that task. The other three types of hazard analysis are explained
above.

164
 Tools: Hazard Analysis, Inspections, Investigations
Workplace examined closely on a
regular basis for the purpose of
• Identifying and recording
hazards
Potential
Actual
•Ensuring that existing hazard
controls are functioning
Certified Safety Auditor Course

The second tool of the safety auditor is inspections.

165
 Tools: Hazard Analysis, Inspections, Investigations
The Initial Accident Scene
Investigation
Managing the Accident
Investigation
Collecting Data
Analyzing Data
Developing Conclusions and
Judgments
Reporting the Results

In the third tool is investigations.

166
3 Primary Tools of the Safety
Auditor
Hazard Analysis
Inspections
Accident/Incident
Investigation
Much too in depth to cover here. Take
the Certified Safety Auditor Course

167
Dealing with the
Hazards You
Discover in Your
Safety Audit

168
 Hazard Abatement
1. Engineering Controls
2. Administrative Controls
a) Plans, Programs, Policies,
and Procedures
b) Training

3. PPE

There is a distinct hierarchy of solutions for the hazards that you discover.
First, if the hazard can be engineered away then it must be. If it is not possible
to engineer away the hazard then it should be controlled with administrative
controls. Administrative controls may be as simple as not allowing employees
to enter a hazardous area. Only if the hazard can not be abated with
engineering controls or administrative controls do we use PPE. In the first two
priorities we either remove the hazard or remove the person who could be
injured. When we use PPE the hazard still exists and the employee is still in
close proximity to it.

169
 Training
Exposing Employees to
Information
Notify, inform
Performance Oriented
Requirements
must know whatever is
necessary to safely perform
must know what your
plans/programs require
Specified Training Requirements
100% Retention

Some OSHA training requirements only require employees to be exposed to

certain information. For example HAZCOM requires that employees be trained
in the safe handling of hazardous materials as indicated on the SDS. But
instead of requiring the employee to memorize the SDS, OSHA requires that
the employee have access to the SDS.

OSHA regulations are broad and general in order that they may apply to a wide
variety of business and industry. It is your responsibility to make the
requirements site specific. Many OSHA regulations are performance oriented
for this reason.

Then there are specific training requirements in OSHA regulations requiring

specific knowledge. Many trainers teach classes covering such regulations and
then give a final exam with a passing score of 70%. OSHA does not say an
employee has to have 70% of the knowledge they require. They must have
100% of the knowledge OSHA requires.

170
Proper Documentation of Training
regulatory requirements
certification of trainer's qualifications to
teach the specific subject matter
objectives of the training course
• initialed by the student certifying they
covered and understand each
method and results of student evaluation
signed statement from the student
certifying attendance and understanding

171
 Plans, Programs, Policies,
and Procedures Required
by Regulations
1.
1. Access
Access to
to Records
Records Procedures
Procedures
2.
2. Acrylonitrile
Acrylonitrile Compliance
Compliance Program
Program
3.
3. Asbestos
Asbestos Compliance
Compliance Program
Program
4.
4. Benzene
Benzene Compliance
Compliance Program
Program
5.
5. Bloodborne
Bloodborne Pathogens
Pathogens Exposure
Exposure Control
Control Plan
Plan
6. Cadmium Compliance Program
6. Cadmium Compliance Program
7.
7. Carcinogen
Carcinogen Program
Program
8.
8. Chemical
Chemical Hygiene
Hygiene Safety
Safety Program
Program
9.
9. Coke
Coke Oven
Oven Emissions
Emissions Compliance
Compliance Programs
Programs
10.
10. Confined
Confined Space
Space Program
Program

These four slides exemplify some of the required plans, programs, policies,
and procedures required by regulators. Not every requirement applies to you.
This is simply to give you an idea of how many requirements exist.

172
11. Contingency Plan
12. Derricks Inspection Procedures
13. 1,2-
1,2-dibromo-
dibromo-3-chloropropane Compliance Program
14. Diving Program (Commercial)
15. Emergency Response Plan
16. Emergency Action Plan
17. Employee Alarm System Procedures
18. Employee Training Program
19. Site Safety and Health Program
20. Ergonomics Program
21. Ethylene Oxide Compliance Program
22. Fire Prevention Plan
23. Formaldehyde Leak and Spill Detection Program
24. Hand and Portable Powered Tools
25. Hazard Communication Program
26. Hazardous Waste Management Program
27. Hazardous Waste Minimization Plan

173
28. Hearing Conservation Program
29. Inorganic Arsenic Compliance Program
30. Ladder Inspection Program
31. Lead Compliance Program
32. Lockout/Tagout Program
33. Mechanical Power Presses Inspection Program
34. Medical and First Aid Checklist
35. Medical Surveillance Program
36. Methylenedianiline Written Plan
37. OPA Plan (Oil Pollution Act)
38. Overhead & Gantry Cranes Preventive Maintenance Program
39. Personal Protective Equipment Policies/Procedures
40. Personal Protective Equipment Program Hazard Assessment
41. Powered Industrial Truck Program
42. Powered Platforms/Manlifts
Platforms/Manlifts/Vehicle
/Vehicle--Mounted Platform
Checklists
43. Process Safety Management Program

174
44. Respiratory Protection Program
45. Safety and Health Program
46. Safety Training & Ed. Program for Construction
47. SARA Title III Report & Plan
48. Servicing Multi & Single Piece Rim Wheels Safe Procedures
49. Sling Inspection Program 1910.184
50. Spill Prevention, Control, and Countermeasures Plan
51. Spill Containment Program
52. Tuberculosis Program 1910.139
53. UST Management Program
54. Vinyl Chloride Exposure Program
55. Walking/Working Surfaces/Fall Protection Policies/Procedures
56. Welding, Cutting and Brazing Policies/Procedures
57. Wiring Design & Protection Equip. Grounding Conductor
Program
58. EPA Risk Management Plan

175
 Plans, Programs, Policies, and
Procedures
Detail
oo Site Specific
oo Area Specific
oo Machine Specific
oo Person Specific
Step -by-step Procedures
Step-by-step
Employee Involvement
o Safety Committees

I have seen many safety plans and programs that were merely a restatement of
the standard. These serve no useful purpose and do not meet the requirements
of the standard. You must take the standard and make it specific to your
situation. You then write step-by-step procedures for your employees to use in
order to safely perform the task.

176
 OSHA’s Inspection
Process
Plans, Programs,
Policies,
Procedures
Training
Hazards
In a programmed inspection, OSHA will check to see that you have all of your
required plans, programs, policies and procedures. They will be checked to
see that they are appropriate. Afterwards, some of your training records will be
checked. If these programs and records are in good order, it will set a very
positive tone for the rest of the inspection. If these records are poor, then a
negative tone will be set for the remainder of the inspection.

177
 Inspection
Inspection
Priorities
Priorities
Imminent Danger
Catastrophes, Fatalities
Complaints
Referrals
Programmed
Inspections
Follow-Up Inspections

OSHA performs inspections by priorities.

The highest priority is an imminent danger. That means someone

is likely to be killed or seriously injured soon because of the
hazard. This would take priority over other inspections.

The second priority is catastrophes and fatalities. These will take

priority over anything except an imminent danger.

Complaints are generally employee complaints and are followed

up in one of two ways by OSHA. OSHA may send an inspector to
check the specific complaint or they may send you a letter
explaining the complaint and offering you the chance to correct it.
They will ask you to take photos of the hazard as it exists, then
correct the hazard, then take photos of the corrected hazard. They
will ask for these to be submitted along with a written report.

Referrals are simply referrals from another agency to OSHA.

178
 The Top 10
Indications That
Your OSHA
Inspection is
Going Badly

179
 Your
Your Inspection
Inspection is
is Going
Going Badly
Badly if:
if:
10. Your Employees
burst into rousing
applause when the
compliance officer enters
the production area.

180
 Your
Your Inspection
Inspection isis Going
Going
Badly
Badly if:
if:
9. The Compliance
Officer asks
where the closest
extended stay
motel is.

181
 Your
Your Inspection
Inspection isis Going
Going
Badly
Badly if:
if:
8. The Compliance
Officer swaggers in
wearing his citation
book in a quick draw
holster.

182
 Your
Your Inspection
Inspection isis Going
Going
Badly
Badly if:
if:
7. The Compliance
Officer has to wear a
dust mask to review
your plans and
programs.

183
 Your
Your Inspection
Inspection isis Going
Going
Badly
Badly if:
if:
6. The Compliance Officer
begins the opening
conference with:
““You
You have the right to
remain silent
silent””

184
 Your
Your Inspection
Inspection isis Going
Going
Badly
Badly if:
if:
5. The employee complaint
received by OSHA refers to
you as a ““filthy
filthy capitalist pig
living off the sweat and
blood of the working man man” ”
and the caller was your
mother.

185
 Your
Your Inspection
Inspection isis Going
Going
Badly
Badly if:
if:
4. The Compliance Officer
ask for the name and
phone number of your
““next
next of kin”.
kin”.

186
 Your
Your Inspection
Inspection isis Going
Going
Badly
Badly if:
if:
3. OSHA sets up a
temporary office in
your parking lot.

187
 Your
Your Inspection
Inspection isis Going
Going
Badly
Badly if:
if:

2. ““60
60 Minutes
Minutes””
shows up to
film the
inspection.

188
 Your
Your Inspection
Inspection isis Going
Going
Badly
Badly if:
if:
1. The Compliance
Officer is the
Safety Director
that you fired last
month.

189
 Voluntary
Voluntary
Compliance
Compliance
Exempt
Exempt from
from fines/citations
fines/citations
on
on initial
initial inspection
inspection only
only
OSHA
OSHA can
can change
change their
their mind
mind in
in the
the
middle of the Inspection
middle of the Inspection
Exempt
Exempt from
from Programmed
Programmed
Inspections
Inspections ONLY
ONLY
Required
Required Abatement
Abatement
How
How to
to Prepare
Prepare
When you join OSHA’s voluntary compliance program you are doing a wise
thing, but first there are a few things you need to know.

You are exempt from programmed inspections only and that’s only because
OSHA is going to make an inspection a part of the VPP process.

When OSHA makes their inspection, you will be required to abate all hazards
they find within certain time requirements.

If you want to join the VPP program it is best to hire a consultant to come in
and do a mock OSHA inspection first. Then, fix everything found in that
inspection and join the VPP program after that.

190
 Voluntary
Voluntary Compliance
Compliance
Safety
Safety Compliance
Compliance AlertAlert
May 21, 1998
May 21, 1998
Are
Are OSHAOSHA consultations
consultations worth
worth the
the
risk?
risk?
““II ff you've
you've ever
ever considered
considered inviting
inviting
an OSHA consultant into
an OSHA consultant into your your
workplace,
workplace, but but hesitated,
hesitated, your
your
instinct
instinct waswas right.
right. You
You never
never know
know
ifif your
your address
address will
will wind
wind upup in
in the
the
computer
computer for for OSHA's
OSHA's enforcement
enforcement
side. Referrals from
side. Referrals from the the
consultation
consultation arm arm are
are investigated.
investigated.
The
The onlyonly exception
exception is is for
for certain
certain
methylene chloride
methylene chloride violations.
violations.” ”

191
End Section

192