NACOSH PRESENTATION

Presented by:
Thomas F. Bresnahan, CSP
Deputy Executive Director

Steven F. Kane, CSP, PE
Chairman, Z490 Committee

September 14, 2000
Washington, DC

Use of the Proposed Z490
Voluntary National Consensus Standard
to Improve Safety, Health, and Environmental Training in Both the Private and Public Sectors

"Good Morning."

Thank you, Mr. Chairman and members of NACOSH, for the opportunity to speak to you here today. My name is Tom Bresnahan, and it is my honor to speak for and represent the 33,000 members of the American Society of Safety Engineers where I am Deputy Executive Director, providing strategic planning in the area of voluntary national consensus standards. I served four years as chairman of the ANSI Safety and Health Standards Board, including chair of the ANSI-OSHA Coordinating Committee. Currently, I am secretary of the ANSI Z490 Standards Committee.

A little later in this presentation you will hear from Steve Kane who is the Chairman of the ANSI accredited Z490 Committee, Best Practices in Safety, Health, and Environmental Training. Our intent this morning is to speak for approximately 15 to 20 minutes - I'll probably run over - and then answer any questions that you may have on the project.

The American Society of Safety Engineers (ASSE) is the oldest and largest society of safety professionals in the world. Founded in 1911, ASSE represents almost 33,000 dedicated safety professionals. However, rather than using my time describing ASSE in great length, let me, for such detail, refer you to the Fact Sheet and other descriptive documents we provided Joanne Goddell. In the Fact Sheet, you will note ASSE's standards activities. Specifically, we are the secretariat of eight (8) American National Standards Committees, which were just reaccredited with high marks, making the Society the largest holder of safety/health standards projects. This involvement goes back to 1921 with the secretariat of A14 Ladder Standards, which makes ASSE an ANSI charter secretariat. In addition, we have over forty (40) safety professionals/ASSE representatives serving on various ANSI, NFPA, ASME, and ASTM committees.

The Z490 Standard
The charter of the American National Standards Committee, Z490 Criteria for Best Practices in Safety, Health and Environmental Training, was accredited by the American National Standards Institute on April 1, 1998. This Standard grew out of the recognized need for improvement in safety, health, and environmental training. Quality training is required to ensure that workers and safety, health, and environmental professionals have the knowledge, skills, and abilities necessary to protect themselves and others in the workplace. OSHA itself has continued to wrestle with training issues on both an internal and external basis for many years. This includes everything from training requirements for specific standards to the potential accreditation of specific training programs. However, for the sake of the issue we are attempting to address please allow me to present a more detailed history of what drove the decision to launch this project:

Four (4) years ago, April, 1996, the ASSE conducted focus group meetings across the country...two (2) in Houston, two (2) in Chicago, two (2) in Gaithersburg, MD, involving over a hundred training experts from business, industry, professional societies, trade associations, training providers, large and small the Mom and Pop operations. The purpose of the meetings was to learn if the ASSE should venture into accreditation of training organizations programs as well as ascertaining the market interest in procuring such accreditation. The Society hired an organization expert in facilitating these accreditation efforts.

I attended four (4) of the six (6) meetings and came away from the discussions with two (2) views...the consultant wanted to sell ASSE on staying the course to put in place an accreditation program, and my second view or impression was that most of (more than half of the participants) despite the consultants "stressing," wanted standards. After much analysis, further discussion, even including the consultant, and more debate, the consensus was for ASSE to pursue an American National Standards training standards project.

The rationale we offered ANSI in filing the application for establishing the project was that these safety, health, and environmental training standards will improve areas of competence, quality and effectiveness. Their potential is to obtain standards of quality which ensure that safety and health training providers meet such standards. The standards of Best Practice, now called Accepted Practice, can help employers and consumers of training services select quality safety and health training materials, instructors, and other program components. Once established, these standards can be used to audit, monitor, evaluate, analyze, etc. national, industry-wide training of large and small training service providers as well as for corporations and government entities seeking third-party review of their employee training activities.

Adding weight to this rationale was the approval of the ANS Z390.1-1995 standard, Accepted Practices for H2S Training, where industry demonstrated its support for such training criteria. This validation presented convincing testimony to show that affected parties/interest groups would support these types of standards development. This translated to a committee whose membership you have just seen, which operates under ANSI rules and procedures. Let me digress for a moment on Z390.1...it has been translated to Spanish for use in the South American oil industry, and it has become a contract between providers and customers.

A review of the foreword and explanatory sections clearly indicates that the ANSI accredited Z490 Committee has taken the position that safety, health, and environmental training is an important element of an effective and efficient overall safety, health, and environmental program. Historically, safety, health, and environmental training has been addressed by only a few regulations with limited scope, such as asbestos, hazard communication, and stormwater management. The regulations usually specify the technical requirements to be addressed in a training course, but do not stipulate how to adequately design, develop, deliver, and evaluate training. This Standard covers all facets of training, including training development, delivery, evaluation, and management of training and training programs. The criteria were developed by combining accepted practices in the training industry with those from the safety, health, and environmental industries. The Standard is intended and can apply to a broad range of training and training programs.

Industry employers and federal/state public policy leaders may use this Standard to assess the services of external training providers, for auditing, or to improve their own corporate training programs. Training providers may use the standard to assess and improve their training services. This standard may also be used as a basis for development and management of training and training programs, with the annexes and references providing additional information and detail. Some governmental regulations specify mandatory requirements for various safety, health, and environmental training. Likewise, the training program may be embedded in a larger safety, human resources, or other organizational structure. As a broad-based voluntary consensus standard, this document complements the regulations and organizational policies. However, it is important to note that compliance with this standard does not assure compliance with governmental regulations or organizational policies, or vice versa.

With that brief overview of the history of the Z490 project, I would now like to turn over the next portion of the presentation to Mr. Steve Kane, Chairman of the ANSI accredited Z490 Committee who will give you an overview of what is included in the draft standard.

Mr. Kane Speaks:
Thank you, I would also like to extend my appreciation to NACOSH for allowing us to speak today on what is a very important issue, the draft ANSI Z490 Standard.

Perhaps, I should begin by pointing out that committee approval of the Standard does not imply that all members voted for its approval. Voluntary national consensus standards are created via consensus and not complete unanimity. At the present time there are members of 48 national organizations - eight (8) of which are observers - on the ANSI accredited Z490 committee, representing a wide variety of public and private stakeholders including business, industry, government, academia, organized labor, training organizations, and professional associations and societies. Our intent is to have as much diversity on the committee as possible to ensure a wide variety of comment and feedback. After a series of meetings and significant effort, the Z490 draft standard went out for its first public review on 7/14/00 with an ending date of 8/28/00.

What does Z490.1 look like? The format of the standard, whether split page or with appendices, has been determined...it is a mixed format of both. Split page is where the left column sets forth requirements, or mandatory provisions, while the right hand column illustrates or offers Examples or Explanations.

Almost all standards have a Foreword - Z490.1 is no exception. While not a part of the standard, the foreword gives the history of establishing the ANSI standards project and some of the reasons for the project, followed by a listing of the organizations and members of the standards committee who developed the standard. A decision has been made to add other elements to the Foreword. They are:

  • audience definitions
  • what and how to use appendices
  • training provider selection
  • training as part of the larger safety system and the need for organizational support as well as links to regulatory requirements

Title of Standard

Alphanumerical designation Z490.1

  • Point 1 means it is the first standard in the project series and, after .1, the year of approval. So it will be Z490.1-2000 Criteria for Accepted Practices in Safety, Health, and Environmental Training.
  • The words in the title capture the key words in the subject matter of the standard and also describe the standard in a shorthand fashion. The committee did contend over best or accepted practices, opting for accepted in view of best being too idealistic rather than consolidating and codifying current existing practices for the first time.

You have already received the draft standard. However, we are proving a brief outline of the different sections in the Z490.1 draft standard, which are as follows:

Section #1
The first section encompasses the Scope, Purpose, and Application sections of the standard. These stipulations are crucial to a voluntary national consensus standard since it establishes the extent and limitations of the standard. This includes:

  • Scope: This Standard establishes voluntary criteria for safety, health, and environmental training programs, including development, delivery, evaluation and program management.
  • Purpose: The purpose of this Standard is to provide accepted practices for safety, health, and environmental training.
  • Application: This Standard is recommended for voluntary application by training providers of safety, health, and environmental training. If any of the provisions of this Standard are deemed to not be applicable, the other requirements or recommendations of the Standard shall still apply. This Standard applies to all safety, health, or environmental training, whether separate or a portion of other training.

Section #2
The second section contains definitions addressing safety, health, and environmental training. These definitions were drawn from either existing materials or arrived at via consensus of the committee.

Section #3
The third section addresses training program administration and management. The committee members believe this is an important part of the standard since training programs are most effective and efficient when managed under a well-defined and organized administrative system. Such a system is designed to assure that training is in an integrated program, rather than a series of non-related training events.

Section #4
This section addresses training development and specifically provides criteria for training that will improve the occupational safety, health, or environmental knowledge, skills, or abilities used by the trainees in the performance of their jobs. This includes a needs assessment, learning objectives and prerequisites, course design, evaluation strategy, and commitment to continuous improvement.

Section #5
Section #5 addresses training delivery. The purpose of this section is to describe acceptable criteria for safety, health, and environmental trainers, and to describe training material delivery requirements. This includes trainer criteria, training delivery, and feedback and communication.

Section #6
Section #6 addresses training evaluation. Training evaluation tools may measure trainee, trainer, training event, or training program performance. The standard provides guidance on evaluation approaches, and commitment to continuous improvement.

Section #7
This section on documentation and record keeping generated significant discussion, as our intent is to provide guidance on a viable documentation and recordkeeping system that would maintain needed information while not creating a burdensome process. Certain regulations already require specific records to be kept for proof of completion of required training. Organizations also may desire to keep additional records to demonstrate their training efforts for control of potential liability issues.

Final Portions of the Standards
The finals sections of the standard are informative annexes, which include:

Annex A - References
Annex B - Training Course Development Guidelines
Annex C - Training Delivery

At this point, I thank you for your time and will now turn the rest of the presentation back over to Tom Bresnahan.

Mr. Bresnahan Speaks:

How Does This Standard Impact OSHA???
The main question from NACOSH appears to be: how does this standard impact OSHA and the training of compliance officers? The answer is that this is a voluntary guideline, but it could eventually have significant impact on the Agency and its compliance officers.

It is no secret that ASSE has long been a proponent of enhanced training for OSHA compliance officers. In fact, our historic position has been that better training for compliance officers would go a long way in improving the reputation of the Agency to a wide range of stakeholders. On too many occasions there have been times when due to limitations of knowledge or expertise, a compliance officer was not able to effectively review hazard analysis, identification, and abatement. At times, the emphasis instead, has been placed on reviewing records or ensuring that a poster is placed in its proper location. We are not saying that posters and records should not be checked - they should. However, at the same time the level of professionalism needs to be increased so that compliance officers are better able to appreciate, understand, and address hazards in today's high-tech environment.

One of the key applications for compliance officers will be that it provides a guideline on how quality training should be conducted. From a professional development point of view, the Z490 project will provide to OSHA and other agencies such as NIOSH, accepted guidelines on how training is evaluated, designed, and implemented. Also, it is important to remember that government agencies are extremely well-represented on the committee, and their views have been consolidated into the draft standard. The bottom line question really appears to be - will this standard have impact on "John Q. Compliance Officer" in the short term. The answer is probably "no", but we believe it could have significant impact in the long-term.

Also, and perhaps of key importance, is the fact that this project provides a 30,000 foot view of safety, health, and environmental training. One of the issues brought up during committee debate was the Z490 standard is similar to many training standards. The view has been raised that it really does not have direct impact on specific applications of safety, health, and environmental training. Before going any further it is important to point again that the broad applications of the standard are designed that way by intent. It is not the intention of the Z490 Committee to attempt to address every aspect of safety, health, and environmental training in one comprehensive document. Such an approach would not be effective and would be a disservice to the key objectives we are trying to achieve.

Our hope is that with this standard as a basic guideline, additional projects will provide training standards on specific applications. For example, the ANSI accredited Z359 Committee, Safety Requirements for Personal Fall Arrest Systems, Subsystems, and Components, is considering launching a project on training for fall protection systems in general industry. Effective training for fall protection is an issue the Z359 committee, the private sector, and government agencies such as OSHA continue to wrestle with. The possibility is there for the Z359 Committee to write a standard, which cites the Z490 standard, but can then specifically address the technical aspects of fall protection training. Such a process will empower more effective and efficient standards to be written for specific safety, health, and environmental training applications. Another existing example is the ANSI Z390 standard, Accepted Practices for Hydrogen Sulfide (H2S) Safety Training Programs. When the standard is revised during the next reaffirmation process, the Z390 Committee will be able to cite the Z490 Standard as a general guideline and then cite the technical specifics of H2S training.

Once again, how does this tie-in to the impact on the compliance officer and OSHA? We see significant long-term impact from the professional development and knowledge perspective. Once additional projects are launched addressing specific technical issues, compliance officers will have more effective training opportunities to expand their personal and professional knowledge base. We cited the Z390 standard since our view is that any compliance officer working with hydrogen sulfide should have in-depth knowledge of the Z390 standard. Such knowledge allows the compliance officer to have professional knowledge of not only the subject matter itself, but also how such hazards are addressed in the private sector. Is this important for OSHA Compliance Officers - you bet it is. This is exactly the type of professional knowledge, which will enable to the Agency to move into the future in a more positive manner. We believe the same thing should happen with compliance officers as new projects come on board. If the goal is to enhance and improve the compliance officer's working knowledge of cutting edge safety, health, and environmental information, involvement with voluntary consensus standards is one of the first places to start.

Let me set forth what the Z490.1 Standard can do:

  • it provides a measurement and benchmark for CSHOs to evaluate training
  • it is a basic body of knowledge to train CSHOs
  • it provides a level of performance whereby training quality can be judged and objectively evaluated
  • it provides audible criteria to evaluate current accepted practices in training, which CSHOs cannot be aware of in the welter of technical issues they are confronted with

    If I may, I would make again the point, phrased differently, that I made in February that OSHA standards committee representatives are kept technically current at minimum cost and are provided with professional development, as well as job enrichment just by serving on these committees.
  • it provides, in the consultative mode, an authoritative reference for selling recommendations to management
  • it describes, at this point in time, the best in safety/health/ environmental training
  • it provides models of training, which are transferable to almost all industries
Finally, as "kudos" to OSHA, we believe it is important to commend the Agency for recognizing the need to enhance the training programs of its staff safety and health professionals. The 7/28 final policy statement on the release of audit documents is important since it specifically noted that training of OSHA field personnel is a priority. Addressing the training needs of compliance officers is a positive first step in a long road that must be traveled by OSHA.

In the training of CSHOs, state plan officers, and related consultants, the Z490.1 Standard should become a cornerstone and established course. Yet, as safety professionals, we must urge the agency to strive to raise the expertise and professionalism of its staff. How do do so?

  • Create a career path for each of the entry points of staff
  • Provide an internal auditing function within the agency monitoring and reporting progress toward individual career goals
  • Please indulge me again with a digression to my earlier NACOSH presentation by suggesting the professional society and association office within OSHA would address this task
  • Create an environment where goals of attaining professional credentials are encouraged throughout the agency, not just national…make it a cultural component of the agency ö you're hired, we are going to make you the best you can be…just like the Marines with an esprit corp

Finally, our last comment is not meant to be a commercial advertisement, but we truly believe it would be of significant benefit to compliance officers if they actively participated in professional safety organizations such as ASSE. When participation and synergy is increased, there is more opportunity for compliance officers to reach out to industry safety professionals to receive additional education and training. Likewise, our members can also significantly benefit by networking with them and learning their points of view. This is a continuation of growing toward a partnership role as opposed to an adversarial role.

With that ASSE concludes its presentation. Steve and I are happy to answer any questions that you may have.

     

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