Documentation is legal proof of something you haveaccomplished. Documentation is written proof and it is designed to demonstrateyour accomplishment to regulatory agencies. In the event of legal actiondocumentation is part of your legal defense. To demonstrate your proof thedocumentation must be written, or you must otherwise be able to reconstruct ordemonstrate what you’re trying to proof. A written safety manual is proof thatyou have written policies and procedures, but that’s all you can prove. In alegal sense for a safety program to be proven effective, and to prove thatthese policies and procedures are enforced you must show some documentation tothat effect. As an example, your company’s policies and procedures require thatevery employee be provided safety orientation training designed to trainemployees in the general hazards to which they may be exposed in their workenvironment. You must prove that this training was conducted.
What type of training is required? Well, safety laws do notspecify how to train, or what format is best, it’s up to each organization todetermine the best training methods. Lectures, videos, slides, or other typesof training are allowed, however you must be able to prove what information wasprovided. If it’s by lecture you must show a lesson plan outlining exactly whatwas taught in this training session. If you train using video the video itselfmay provide ample documentation of what was contained in the training. The nextstep is to prove that the employee received the training: A training log, testquestions answered by the employee, and a signature of the employee certifyingthat he or she received the training. Signatures don’t necessarily proveanything because some legal because some legal cases have determined that theemployee was told to read and sign a document but the employee stated that hereally didn’t read it, although he signed the document. It’s always best thatthe person who provides the training certify what information was taught, whoattended the training, and the time and date of the training. This informationshould then be retained in company files for 5 or more years.
Recommendation: when training is conducted whether its videoor any other format hands on training should be conducted as well. An examplewould be forklift operator training. Certainly safety information could be providedin a classroom setting. However, operators should demonstrate their ability tooperate the equipment satisfactorily. A safe lifting video is great forteaching the basics, but until a person actually demonstrates the safe way tolift you can’t be sure the person actually knows how to lift safely. The sameapplies to fire extinguisher training. A video teaching the basics is great,but there’s no substitute for actual hands-on use of fire extinguishers. Besure to document the fact that hands on training was conducted and the employeedemonstrated an ability to assimilate the training. What documents arerequired? Well, that decision is made by your organization. As a minimumhowever 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 thename of the lesson outline, the title of the video, or other information thatadequately describes the information taught
Although not a requirement, it is recommended that eachperson attending the training be given a short quiz, and provide answers to thequiz. The person taking the test would also verify by giving a signature, andprinted name, with the date of the test. Those employees given oral tests inlieu of written tests should also acknowledge by written documentation that thetest was given and answered.