Excerpt: Documentation is legal proof of something you have
accomplished. Documentation is written proof and it is designed to demonstrate
your accomplishment to regulatory agencies. In the event of legal action
documentation is part of your legal defense. To demonstrate your proof the
documentation must be written, or you must otherwise be able to reconstruct or
demonstrate what you’re trying to proof. A written safety manual is proof that
you have written policies and procedures, but that’s all you can prove. In a
legal sense for a safety program to be proven effective, and to prove that
these policies and procedures are enforced you must show some documentation to
that effect. As an example, your company’s policies and procedures require that
every employee be provided safety orientation training designed to train
employees in the general hazards to which they may be exposed in their work
environment. You must prove that this training was conducted.
What type of training is required? Well, safety laws do not
specify how to train, or what format is best, it’s up to each organization to
determine the best training methods. Lectures, videos, slides, or other types
of training are allowed, however you must be able to prove what information was
provided. If it’s by lecture you must show a lesson plan outlining exactly what
was taught in this training session. If you train using video the video itself
may provide ample documentation of what was contained in the training. The next
step is to prove that the employee received the training: A training log, test
questions answered by the employee, and a signature of the employee certifying
that he or she received the training. Signatures don’t necessarily prove
anything because some legal because some legal cases have determined that the
employee was told to read and sign a document but the employee stated that he
really didn’t read it, although he signed the document. It’s always best that
the person who provides the training certify what information was taught, who
attended the training, and the time and date of the training. This information
should then be retained in company files for 5 or more years.
Recommendation: when training is conducted whether its video
or any other format hands on training should be conducted as well. An example
would be forklift operator training. Certainly safety information could be provided
in a classroom setting. However, operators should demonstrate their ability to
operate the equipment satisfactorily. A safe lifting video is great for
teaching the basics, but until a person actually demonstrates the safe way to
lift you can’t be sure the person actually knows how to lift safely. The same
applies to fire extinguisher training. A video teaching the basics is great,
but there’s no substitute for actual hands-on use of fire extinguishers. Be
sure to document the fact that hands on training was conducted and the employee
demonstrated an ability to assimilate the training. What documents are
required? Well, that decision is made by your organization. As a minimum
however the following information should be documented.
- Date and time of training.
- Who conducted the training.
- Who attended the training.
- What specific information was taught? Now this could be the
name of the lesson outline, the title of the video, or other information that
adequately describes the information taught
Although not a requirement, it is recommended that each
person attending the training be given a short quiz, and provide answers to the
quiz. The person taking the test would also verify by giving a signature, and
printed name, with the date of the test. Those employees given oral tests in
lieu of written tests should also acknowledge by written documentation that the
test was given and answered.
