Economical Training

There are many companies that provide training programs, seminars and videos. However, this book was designed for small companies. Large companies that provide training for large corporations charge a lot of money because their training is for large staffs. It is not unusual to pay over $1500 for a single training program. As you will learn, one video is not enough. It is likely that you will pay thousands to train your staff if you plan to acquire all the videos. Here are some ideas on how to cut these costs.

CAE Consultants Inc. specializes in written programs. Some of our plans have simple PC slide shows that can be used for training or refreshers. Call (914)963-3695 to see if we have a written plan for your industry and if it has a PC slide show. 

Insurance company is often a little-known source of FREE training and most businesses don't even know it. Even if you have a small policy with a company like AETNA for example, they will train you free of charge! Courses they provide are very comprehensive. The only requirement is that you send personnel to their site. 

Community colleges and state programs may provide additional low cost sources of training. Check all available resources in your community, including the fire department, the police, your sewage treatment and water system plants. Find out where they train and what it would cost you. 

Local business libraries, society libraries, or trade libraries or non-profit groups in your area may allow you to borrow materials for a period. 

Government training materials are generally less expensive, but not much more. For example, OSHA courses require you to travel to their site and they still run several hundred dollars. You can rent videos from certain companies, like ITS, Their videos are expensive but rentals are quite reasonable. The library of congress may allow borrowing and some State libraries may have materials they can mail to you. Check it out. Local consultants may not be as expensive as you think.

They may have materials ready and their fees to offer several courses could be reasonable, particularly if you combine this with other businesses. Work with your local technical society or chamber of commerce to see if you can do joint training with another group. 

You don't really have to go overboard either. You can use a training video, but in most cases, merely setting down with the employee and conveying the more important concepts of your program is sufficient. You can administer your own test. Just be sure that you record everything and make them sign their training completion forms. 

Where states require training, you are stuck having to take their courses and pay their license fees. In New York, for example, obtaining all of the licenses required to handle asbestos runs over $2,000. It is a way to lock people into a particular training program for which someone has contracted. It leaves some trainers out of the business. If you are a small minority business, see if you can get a grant to train your staff. 

Some states put a lot of taxpayer money in developing programs for their government and federal employees. They may have a program to allow local small businesses to share the cost. Call and check it out. Sometimes you can work a special deal with the program director. If they have empty seats in the classroom why let them go to waste? 

Summary of the EPA Asbestos Training Course

The EPA Model Accreditation Plan for asbestos worker training is based on the following specific occupations that have some level of asbestos involvement and exposures.

Asbestos Abatement Workers

A four day training course that includes:

1. At least 14 hours of hands-on training that provides asbestos workers with actual experience performing tasks associated with asbestos abatement work.
2. Topics for the course are to include the physical characteristics of asbestos, potential health effects related to asbestos exposure, employee personal protective equipment, work practices, personal hygiene, medical monitoring, air monitoring, relevant state, local, and federal standards, respiratory protection programs and medical monitoring programs, additional safety hazards on asbestos abatement projects.
3. Course review, and an examination (50 multiple choice questions with 70 percent correct).
4. Individual respirator fit-testing.
5. The EPA training course requirements are found on pages 5252 and 5253 of the February 3, 1994 Federal Register.

An annual refresher training session is required which is to be one full day. The refresher courses are to be conducted as separate and distinct courses, not to be combined with any other training during the period of the refresher course. The refresher course shall review and discuss changes in regulations, developments in state-of-the-art procedures, and a review of key aspects of the initial training course. A recertification examination is at the option of the state.

Awareness Training for Maintenance and Custodial Workers

This training is detailed in 40 CFR 763.92(a)(1). EPA specifies that the training is to be two hours in length and must include, but not be limited to:

1. Information regarding asbestos and its various uses and forms.
2. Information on the health effects associated with asbestos exposure.
3. Locations of asbestos-containing building material identified throughout each school building in which the employee works.
4. Recognition of damage, deterioration, and delamination of asbestos containing building material.
5. Name and telephone number of the person designated to carry out general local education agency responsibilities under 40 CFR 763.84 and the availability and location of the management plan.

EPA does not specify refresher training for this category.

Operations and Maintenance Training Course

The training required by EPA for this course is detailed in sections 40 CFR 763.92(a)(1) and 763.92(a)(2). This course is to be a total of 16 hours, which is two hours for the awareness level portion and 14 hours for the additional training required for operations and maintenance personnel.

The training has to include the same requirements for awareness training, as well as the following additional requirements:

1. Descriptions of the proper methods of handling asbestos containing building material.
2. Information on the use of respiratory protection and other personal protective measures.
3. The provisions of 40 CFR 763.92 and 40 CFR 763.91, Appendices A, B, C, D, EPA regulations contained in 40 CFR Part 763, subpart G, and in 40 CFR Part 61, subpart M, and OSHA regulations contained in 29 CFR 1926.58.
4. Hands-on training in the use of respiratory protection, other personal protective measures, and good work practices.
   
   

Comprehensive Course for Supervisors

The five day training course for supervisors includes:

1. Lectures and demonstrations on the physical characteristics of asbestos and asbestos-containing materials, potential health effects related to asbestos exposure, employee personal protective equipment, work practices, personal hygiene, medical monitoring, air monitoring, relevant state, local, and federal standards, respiratory protection programs and medical monitoring programs, insurance and liability issues, recordkeeping for asbestos abatement projects, supervisory techniques for asbestos abatement activities, and contract specifications.
2. Fourteen hours of hands-on training must permit asbestos workers actual experience in performing tasks associated with asbestos abatement.
3. Individual respirator fit-testing.
4. Course review.
5. Written examination (100 multiple course questions with a passing score of 70 percent).

One full day of refresher training. The refresher courses are to be conducted as separate and distinct courses and not combined with any other training during the period of the refresher course. The refresher course reviews and discusses changes in regulations, developments in state-of-the-art procedures, and reviews key aspects of the initial training course. A recertification examination is at the option of the state.

Information,Training & Communicating Hazards to Employees | ASBESTOS

Communicating Hazards to Employees

Employers and building owners are required to treat installed thermal system insulation (TSI) and sprayed on and troweled-on surfacing materials as asbestos containing material (ACM). Treat asphalt and vinyl flooring material installed no later than 1980 as asbestos-containing.

Employers and building and facility owners must exercise due diligence in complying with requirements to inform employers and employees about the presence and location of ACM and presumed asbestos containing material (PACM).

Building Owner Responsibilities

Building and facility owners have to maintain records of all information required concerning the presence, location and quantity of ACM and PACM in the building/facility. Such records need to be kept for the duration of ownership and must be transferred to successive owners.

Building and facility owners have to inform employers of employees with potential exposure risks. Those employers must inform their employees who will perform housekeeping activities in areas which contain ACM and/or PACM of the presence and location of ACM and PACM in these areas. Identification of ACM and PACM should be made by industrial hygienists, or by persons whose skill and experience in identifying asbestos hazards is the equivalent to that of industrial hygienists.

Information and Training

All employees who are exposed to airborne concentrations of asbestos at or above the action level must be properly trained about asbestos hazards. Training has to be provided prior to or at the time of initial assignment, and at least yearly thereafter.

Training Program Elements

An effective training program must provide employees with information about the health hazards of asbestos exposures and include the following elements:

• Relationship between asbestos and smoking in producing lung cancer;
• Operations which could result in asbestos exposure;
• Engineering controls and appropriate work practices associated with the employee's job assignment;
• Purpose, proper use, and limitations of respirators and protective clothing;
• Medical surveillance program;
• Emergency and clean-up procedures;
• Names, addresses, and phone numbers of public health organizations which provide information, materials, and/or conduct programs concerning smoking cessation; and
• A review of the procedures contained in OSHA's asbestos standard at §1910.1001.

All training materials must be available to the employee without cost and, upon request, to OSHA and NIOSH representatives.

Training | Permit-Required Confined Spaces

All employees who work in permit spaces have to be trained to understand the hazards of confined spaces and obtain the skills necessary to safely perform their assigned duties. Training must be done:

§  Before the employee is first assigned duties;

§  Before there is a change in assigned duties;

§  Whenever there is a change in operations that present a new hazard; and

§  Whenever there are deviations from the entry procedures or inadequacies in an employee’s knowledge are noted.

The employer must certify that the training has been completed. Required training documentation includes each employee’s name, the signatures or initials of the trainers, and the dates of training.

Entrant duties

Authorized permit-required confined space entrants are required to be knowledgeable about the space and their job tasks inside the space to successfully perform their duties which include:

§  Knowing the hazards that may be faced during entry, including information on the mode, signs or symptoms, and consequences of the exposure;

§  Properly use equipment;

§  Communicate with the attendant;

§  Alert the attendant whenever:

o    The entrant recognizes any warning sign or symptom of exposure to a dangerous situation, or

o    The entrant detects a prohibited condition; and

§  Exit from the permit space as quickly as possible whenever:

o    An order to evacuate is given by the attendant or the entry supervisor,

o    The entrant recognizes any warning sign or symptom of exposure to a dangerous situation,

o    The entrant detects a prohibited condition, or

o    An evacuation alarm is activated.

Attendant duties

Authorized permit-required confined space attendants are required to be knowledgeable about the space to successfully perform their duties which include:

§  Knowing the hazards that may be faced during entry, including information on the mode, signs or symptoms, and consequences of the exposure;

§  Being aware of possible behavioral effects of hazard exposure in entrants;

§  Continuously maintain an accurate count of entrants and ensure that the entrants are accurately identified;

§  Remaining outside the space during entry operations until relieved by another attendant;

NOTE: If the entry program allows it, attendants may enter a permit space to attempt a rescue if they have been trained and equipped for rescue operations and if they have been relieved by another attendant.

§  Communicating with entrants to monitor their status and to alert them to evacuate the space, if necessary;

§  Monitoring activities inside and outside the space to determine if it is safe for entrants to remain in the space;

§  Ordering entrants to evacuate the space immediately under any of the following conditions:

o    Detecting a prohibited condition,

o    Noticing the behavioral effects of hazard exposure in an entrant,

o    Detecting a situation outside the space that could endanger the entrants, or

o    Determining that an attendant cannot effectively and safely perform all the required duties;

§  Summoning rescue and other emergency services as soon as it is determined that entrants may need escape assistance;

§  Warning unauthorized personnel to stay away from the permit space, or if they have already entered the space, tell them to exit it;

§  Warning entrants and the entry supervisor if unauthorized persons have entered the space;

§  Performing non-entry rescues, if specified by the employer’s rescue procedure; and

§  Performing no duties that might interfere with the attendant’s primary duty to monitor and protect entrants.

Entry supervisor duties

Permit-required confined space entry supervisors are required to be knowledgeable about the space to successfully perform their duties which include:

§  Knowing the hazards that may be faced during entry, including information on the mode, signs or symptoms, and consequences of the exposure;

§  Verifying, by checking the entry permit, that all tests specified by the permit have been conducted and that all procedures and equipment are in place before endorsing the permit and allowing entry to begin;

§  Terminating the entry and cancelling the permit at the conclusion of work;

§  Verifying that rescue services are available and that the means for summoning them are operable; and

§  Removing unauthorized individuals who enter or who attempt to enter the permit space during entry operations.

Supervisors also must determine, at least when shifts and entry supervisors change, that the acceptable conditions specified in the permit continue.

Elements of Your Training Program | Hazard Communication

A properly conducted training program will ensure comprehension and understanding. It is not sufficient to either just read material to the trainees, or simply hand them material to read. You want to create a climate where workers feel free to ask questions. This will help you to ensure that the information is understood. Always remember that the underlying purpose of hazard communication is to reduce the incidence of chemical source illnesses and injuries.

Your training program can take any form, as long as the required information is conveyed and understood. You will probably need to make adjustments, depending upon the level of employee you are training. Take into consideration the education and technical background of the trainees. At a minimum, cover the following topics.

Hazard Communication Standard

Employees must be informed of the existence of the HCS, what the standard requires, and what it will do for them. Explain that the purpose of the HCS is to ensure that the hazards of all chemicals produced are evaluated, and that information concerning these hazards is transmitted to employers and employees.

Terminology — Are we speaking the same language?

Before you proceed too far with your training program, clarify the language you will use. Don’t assume that workers know what an MSDS is, or a hazard warning. The less educated your workers, the more you will need to explain the terminology. Use handouts, diagrams, draw pictures on a chalk board — whatever is necessary to communicate your message.

Material safety data sheets

Determine ahead of time how much MSDS information you feel is necessary and will be useful and understood. Explain what the MSDS is and its purpose. Explain the categories on the MSDS, the kind of information found in each section, and what some of the terms mean. Don’t overload the employees with terminology. They should just understand what is relevant and important to their interaction with chemicals.

Knowing the effects of overexposure of chemicals they use everyday is extremely important. Their understanding of the value of the information in “routes of entry” can increase PPE use. Emphasize the areas that should matter to them. Bring the information into the “real” world. Use examples of how this information can protect them in their own workplace.

The most vital information in this part of the training is explaining where the data sheets are kept and how to access them. If you are keeping your MSDSs in a binder or book, hold it up, pass it around, familiarize the trainees with it. Make sure the book or binder is clearly marked and explain where to find it in the work area. Remember, during an inspection, OSHA will ask employees if they know where to find the MSDSs.

Labels

Labels are the most visible and most frequent contact your employees will have with chemical information. Labels are intended to serve as an immediate visual warning of the hazards of the chemical. It is very important that employees have a thorough understanding of how to interpret the information being presented on the label, so that they can modify their handling of the chemical accordingly.

The written program

The written program is your documentation of how you have complied with the Hazard Communication Standard in your company. This program must be made available to your employees. Tell them how they can review the complete written program.

Specific chemicals

This section will comprise the largest part of your training program. You should give specific details on what chemicals the employee has contact with and how to safely handle those chemicals.

Cover how to detect the presence or release of the chemical (visual appearance or odor when being released, monitoring devices, and what they indicate). Thoroughly describe the physical and health hazards of the chemicals in their work area.

You do not need to cover each chemical. Break your chemicals down into groups, such as paints or solvents, and discuss the hazards and precautions of the group as a whole. This saves a lot of time, but also is more effective as a training technique.

Protective equipment

Explain the proper use of protective equipment that is required for the safe handling of the chemicals. Demonstrate how to use the PPE and clearly indicate when the device is to be used, how to care for it, and where it is stored. Explain your company policy regarding the use of protective equipment.

First aid and emergency procedures

Make sure workers understand what first aid and emergency procedures should be used in the event of exposure or overexposure to the hazardous chemicals they work with. Point out where they can find this information on the MSDS, if they have questions in an emergency situation.

Employee certification

Although the Hazard Communication Standard does not require that you record that employees have been trained, it’s a good idea to document who has been trained and when they received training.