We all know that employers should provide health and safety training to employees but why, and what makes good training great? Julie North explains.
Why health and safety training is needed
The Health and Safety at Work Act, etc 1974 states that employers should provide “such information, instruction, training and supervision as is necessary to ensure, so far as is reasonably practicable, the health and safety at work of his employees”. The Management of Health and Safety at Work Regulations 1999 further require that employers provide employees with adequate health and safety training both on recruitment and when the risks to which they are exposed change, eg where they move to a new role or when new work equipment is provided.
The Management of Health and Safety at Work Regulations 1999 go on to state that training should be repeated periodically where appropriate, be adapted to take account of any new or different risks and take place during working hours. Other sets of regulations which require training of employees include the Health and Safety (Display Screen Equipment) Regulations 1992, the Health and Safety (First-Aid) Regulations 1981, the Provision and Use of Work Equipment Regulations 1998 and the Regulatory Reform (Fire Safety) Order 2005.
Organisations that have their health and safety management systems certified, eg to BS OHSAS 18001 or ISO 45001, are also required to conform to requirements concerning competence.
Non-compliance with training requirements
A search on the Health and Safety Executive (HSE) enforcement database throws up numerous results of prohibition and improvement notices for organisations failing to provide employees with adequate information, instruction and training.
Notices cover driving fork lift trucks and using circular saws (under the Provision and Use of Work Equipment Regulations 1998), asbestos (under the Control of Substances Hazardous to Health Regulations 2002) and manual handling operations for packing boxes (under the Manual Handling Operations Regulations 1992). In 2017, a large household goods retailer was fined £2.2 million after a worker was paralysed when a roll cage holding paint fell on her. Investigations into the accident found that employees were not provided with sufficient training on the use of roll cages.
More recently, a beer distribution company was fined £60,000 and ordered to pay costs of £7203.14 when a temporary worker received facial fractures and a brain injury after kegs of beer fell on him while he was attempting to unload a delivery. The investigation found the worker was inexperienced and had not been provided with training for his role on commencement of his employment.
Costs associated with lack of training extend beyond notices and fines. They include costs associated with recruiting and replacing staff when injured people are off work after an accident, retraining staff, injury rehabilitation costs, costs associated with replacing damaged plant and equipment, loss of earnings due to down time for an accident investigation, not to mention possible reputational damage.
Training: who, what, why, where and when
Unfortunately, when it comes to work-related training, there is no one-size-fits-all. Employers should consider who in their organisation needs training, what training should be provided, when, by whom, and when training should be repeated and refreshed. Consideration should also be paid to whether staff require formal qualifications for their role, such as facility managers, first aiders, or the maintenance teams responsible for legionella safety.
While all new joiners should have a general health and safety induction, it is highly likely that all organisations will have additional training needs for their workforce. For example, DSE users will need information and training on its use, staff managing post, deliveries and distribution may need manual handling training, and users of high-risk work equipment and machinery should be given training on its use. Not forgetting employees who take up additional duties such as fire marshals and first aiders.
Organisations may also find their own clients and customers require staff with formal qualifications to demonstrate competence, such as the NEBOSH Diploma or IOSH qualifications.
When is training “sufficient”?
When considering training needs, employers should assess all work activities carried out at their organisation and the equipment used in each role to identify health and safety aspects, hazards of equipment used and therefore the training required. This may identify training requirements not thought about before, such as:
travel safety for staff who work away from the office
stress awareness and mental health training for line managers
event safety for marketing teams
lone working and personal safety training for staff who work alone or with members of the public
training and information needs of visitors and contractors.
There are many other sources of information which can be used to identify training requirements, as follows.
• Specific legislation states what people should be trained on, eg Health and Safety (Display Screen Equipment) Regulations 1992.
• Approved Codes of Practice and Guidance such as L8 Legionnaires' Disease. The Control of Legionella Bacteria in Water Systems. Paragraph 49 states that competent people appointed should receive training on sources of legionella, precautions to take to protect people and the measures to take to ensure legionella controls are effective.
• British Standards. For example, ISO 45001:2018 Occupational Health and Safety Management Systems, Clause 7.2, is dedicated to competence and states that organisation should determine competence requirements of workers that can affect occupational health and safety. Also BS 9999:2017 Fire Safety in the Design, Management and Use of Buildings, Annex Q, gives guidance on fire safety training to be provided at induction, refreshed at least once a year, and recommends that roles such as security and cleaning teams are included in the training regime.
• Manufacturer instructions should detail instructions on how to use equipment safely, which can form part of training provided.
• Suppliers of services or equipment such as fire alarm servicing companies or cleaning substance providers may have a training arm to train your fire marshals or cleaning team on COSHH.
• Organisations can also develop their own training questionnaire to directly ask staff if they have received suitable training, feel competent to carry out their tasks safely and what additional training they may need to address any issues.
If you’re looking to source training from an external provider, take steps to ensure the provider is competent themselves. Ask for evidence of their qualifications in their training field and if they have specific training qualifications (eg are they an IOSH approved trainer or do they have a Level 3 award in education and training?). Also ask to have a look at examples of their previous work, eg example training materials.
Training to meet learners needs
When organisations have identified what training needs to be delivered, they should also think about the people receiving the training — the learners — and the best way to deliver training to meet a wide variety of learning styles or existing expertise. There are many self-assessments available which people can take which indicate what type of learner the individual is. These are usually summed up into three learning categories.
• Visual — people who learn by seeing or observing things such as pictures, videos, diagrams or watching demonstrations.
• Auditory — people who learn by listening, ie through discussions, listening to recordings or reading aloud.
• Kinaesthetic — people who learn by touching and doing such as practical tasks, handling and holding items, drawing and completing “on the job” training.
People will usually have already identified their preferred learning style; however, fortunately most people learn using a blend of all styles, as it is unlikely that employers will have the luxury of being able to train each staff member individually. A course designed to incorporate a good mix of learning styles will benefit a wide range of people.
Where the effectiveness of the training given needs to be checked to demonstrate competence, people often turn to a written exam, which can strike fear into most people at the best of times. Designing a course that meets a wide range of needs should extend to considering various ways in which an end-of-course assessment can be completed. Thinking about the learning styles above, assessment methods could include; learners observing another person carrying out a task to identify what they did wrong, discussions, hazard spotting in pictures, quizzes, quick fire questions and answers, puzzles or practical tasks.
Employers should also think about what adjustments to training may be required to meet varying abilities. This could include using braille, spoken word or computer-based packages. A survey from the Office of National Statistics found that non-UK nationals accounted for 28% of people working in the construction and civil engineering sectors, so reviewing employees’ first languages could be an important factor to consider.
Employers should record their training needs analysis as it can be used to plan for training and refresher training when planning budgets to ensure the right resources are allocated and to demonstrate that training needs have been reviewed.
Evidence of training should be recorded, whether this is in the form of certificates, attendance lists, feedback forms or simply evidence of end of course assessments being completed. You never know when staff training may be called into question.
Julie North is Principal Health and Safety Consultant at System Concepts.
Last reviewed 16 May 2019