Health and safety training - tick box or tactics?
Training in its broadest sense should be designed to improve skills, impart information and/or develop understanding. It is also fundamental to health and safety - whether specifically cited in regulations or as a route to competence – along with experience and knowledge.
The possible scope of health and safety training topics within organisations is extensive and can cover everything from, duty holder to awareness training, accident reporting and investigation, to work at height, fire warden and Legionella responsible person.
This does raise its own challenges though:
- Who needs what level of training?
- How should it be delivered?
- When and how frequently is it needed?
- Can it be done inhouse or need external help?
- Are professional qualifications needed?
- Do I need and does it qualify for CPD?
As a consequence what is actually required and what is being delivered can be different things. Allocating the right level of time and having the right people attend the session can end up as a compromise. The risk here is that providing the training in a format to some or all becomes the focus – “ticking the box” – rather than what its purpose and outcome should be.
When considering your health and safety training here are some aspects you may want to reflect on:
1. How effective is your current health and safety training?
Because it is covered in both the Health and Safety at Work etc. Act 1974 and in the Management of Health and Safety at Work Regulations 1999, as well as a number of specific regulations, the provision of health and safety training is a routine activity in most organisations. But what does the legislation say is its actual purpose? To quote the Health and Safety Executive (HSE):
“The Health and Safety at Work etc. Act 1974 requires you to provide whatever information, instruction, training and supervision as is necessary to ensure, so far as is reasonably practicable, the health and safety at work of your employees.
This is expanded by the Management of Health and Safety at Work Regulations 1999, which identify situations where health and safety training is particularly important, e.g. when people start work, on exposure to new or increased risks and where existing skills may have become rusty or need updating.”
The detail and content therefore needs to reflect the risks each particular staff member or department are likely to be exposed to and the information, instruction, training and supervision they require.
It is not uncommon for us to be providing training for our new customers where 80% of those in attendance have had no previous training in a particular area. While for some it may be a new topic or skill, others have been involved in it for years. Where are you with your current workforce and their task related training?
2. How have you identified your training needs for your organisation?
Understanding the purpose of the training being delivered is crucial to it, not only to provide the right level of information and instruction but also the right skills required. For example, fire evacuation training and information for general staff will be different to that needed for fire wardens, security teams and others involved in the marshalling and management.
Equally those providing more specialist work i.e. Legionella, work at height, electrical, asbestos, fire, work equipment, will have additional training and competence needs.
Default induction training covering health and safety and fire is common. For more job role or task based competencies, training matrices are now a staple for many organisations, providing a clear pathway and expectation. They both need to be timely in their provision; however induction training for someone who has been with the organisations for months may be a bit of an oxymoron.
Regulation 13 Capabilities and training of the Management of Health and Safety at Work Regulations 1999 – states:
(1) Every employer shall, in entrusting tasks to his employees, take into account their capabilities as regards health and safety.
(2) Every employer shall ensure that his employees are provided with adequate health and safety training:-
(a) on their being recruited into the employer’s undertaking; and
(b) on their being exposed to new or increased risks because of :-
(i) their being transferred or given a change of responsibilities within the employer’s undertaking,
(ii) the introduction of new work equipment into or a change respecting work equipment already in use within the employer’s undertaking,
(iii) the introduction of new technology into the employer’s undertaking, or
(iv) the introduction of a new system of work into or a change respecting a system of work already in use within the employer’s undertaking.
The area we support most with is health and safety management and the more specialist risks, particularly around the roles of, for example the responsible person. Where these positions or the risks change, making provision for reviewing and updating training is often an aspect that gets missed.
3. How are you delivering your health and safety training?
Different types of training will lend themselves to different styles of delivery and there is a myriad to choose from. Whether external formal courses, inhouse classroom sessions, webinar, e-learning or video (yes they still exist) all have a place and relevance. The key is to match the delivery method to the content and need of the training.
Time can be the overriding factor here. An employee of Assurity Consulting can recall a site induction where they needed to sit through a site safety induction video as part of the signing in/permit process. Ten minutes in, to what turned out to be a 22 minute video, the security guard knocked on the door to ask if they were ok “as nobody had spent that long watching it before”. Bearing in mind it was on many levels a very high hazard environment, what did that actually say about their permit process? Needless to say it was raised as part of the health and safety assessment Assurity Consulting were there to do and they were recording the times in and out (average time 8 minutes).
People also learn in different ways, some like to see, some like to hear and some like to do, so mixing up styles as a means of reflecting this works well.
Tailor content and format, to the type and style of the training i.e.:
- If it is refresher or update training for an activity someone is performing frequently, eLearning or tool box talks can be really effective.
- Online courses for dip in and out style information based training can also prove beneficial as can a one to many training need such as DSE.
- For more competence focussed training classroom sessions may prove better with a combination of styles.
- Practical, physically doing it, training for manual handling, fire evacuation or extinguishers, work at height and work equipment.
In every case though, have clear objectives and outcomes for your training and keep it as relevant as possible to the topic and work types being performed by those attending. Some organisations like to test following training and other don’t, what is your policy?
4. Who should be delivering your health and safety training?
In reality this will ultimately depend on the budget and time you have available, but perhaps the question should be, putting cost and time to one side, what should this particular training look like?
Training packages now can be very sophisticated, with the ability to develop very specific content directly for your organisation branded and on message. Equally outside organisations can provide the wider “subject matter expert view” nuanced to current trends. With the latter though make sure they are doing their homework and understand your particular situation, the objectives you want to achieve and will tailor content accordingly.
Look at what and how you are providing for your health and safety training and ask yourself the question, “is the way this is being done working, and if not how can I change it?”
5. Some examples of where health and safety training went wrong.
Aldi Stores Ltd was fined £1 million (and £70,000 costs) last year when a recently employed delivery driver, while operating an electric pallet truck, suffered severe foot injuries. The lead Council investigator highlighted, “This accident resulted in very nasty injuries to a driver who had been asked to carry out work using equipment for which his employer had failed to provide structured and necessary formal training.”
Kent County Council were fined £200,000 because, as an employer under the Health and Safety at Work etc. Act 1974, it failed to ensure employees liable to be exposed to asbestos had been trained adequately at a school in Sittingbourne. HSE inspector Kevin Golding commenting to IOSH Magazine said “Neither the caretaker nor the headteacher had any asbestos management or awareness training. Though the council did have policies on providing asbestos training, it had failed to check and monitor that they were being properly followed.”
WK West Ltd trading as Westpack, of Cornish Street, Sheffield, were fined £120,000 in 2016 following an accident involving a circular saw. “They failed to ensure so far as is reasonably practicable, the safety of persons in their employment including Kevin James Allison, in particular that they did not provide such suitable and sufficient assessment, training and supervision as was necessary.”
Following an accident with a waste shredding machine, CP Environmental Limited pleaded guilty to breaching Section 2 (1) of the Health and Safety at Work etc. Act 1974 and fined £34,000 (with £19,226 costs). HSE Inspector Mr David Keane said of the incident, “It could have easily been avoided and it was fortunate that the injuries suffered weren’t more serious. Those in control of work have a responsibility to devise safe methods of working and to provide the necessary information, instruction and training to their workers”.
Assurity Consulting are leading experts in workplace health, safety and environmental compliance. We have provided training on an extensive range of health and safety topics to organisations all over the UK. If you feel that there are areas of your workplace health and safety training that need reviewing, please contact us on tel. +44 (0)1403 269375 or email us. firstname.lastname@example.org