Today, training requirements are much more sophisticated than they were just five years ago. The American National Standards Institute (ANSI) has issued ANSI/ASSE Z490.1-2001, Criteria for Accepted Practices in Safety, Health, and Environmental Training. This new standard establishes criteria for safety, health, and environmental training programs, including development, delivery, evaluation, and program management. It defines competent persons to serve as safety instructors and delineates other trainer requirements. The company EHS manager should know thoroughly the documentation and record keeping mandates of the standard as well as systems and procedures, documentation control and certification. The standard is available from the American Society of Safety Engineers, 1800 East Oakton Street, Des Plaines, IL 60018-2187; phone: 847/699-2929; web site: www.asse.org.

As outlined below, the concrete products industry is subject to a large number of environmental, fleet, safety, and health training requirements for its workers. Training requirements cover not only a wide range of subjects, but also specific topics within each subject area, plus testing, retraining, and documentation. Training is now considered one of the following three basic compliance components of any EHS program:

1. Written safety programs and procedures
2. Inspections, follow-up, and documentation
3. Training and documentation

Training systems are now much more complex: the old system of simply holding a safety meeting and having everyone present sign a sheet describing the training subject has been replaced by a new standard comprising sophisticated course development guidelines, written objectives, course outlines, and testing for comprehension documentation. Many producers are now relying on interactive computer training programs available from a number of safety supply companies.

Although all training applicable to an employee's scope of work is uniformly required before exposure to a particular hazard begins with the employee's assumption of job responsibilities, the time required to successfully train and document a new employee varies from company to company. Preliminary training usually included in New Employee Orientation and documentation is the key to initial training compliance. Since employees tend to trickle in one or several at a time, having a full-time trainer to provide the necessary instruction presents an unreasonable cost burden for the employer. Directing a new employee to a computer where interactive training programs are available in either English or the appropriate second language is a cost-effective method for assuring a consistent standard of training. Yet, on-the-job, one-on-one, and hands-on training remains to be conducted by the supervisor or other designated competent person. All safety training, regardless of mode, must be documented.

Currently, companies must have a computerized system that tracks each employee's training record, scheduled date for retraining, and competency authorization for specific job skills. Gone are the days when a crane or forklift operator's hardhat sticker was sufficient to signify competency, since training is now required for almost every skill. Welding, mobile equipment operation, scaffolding and ladder use, cage cutter or rebar shear operation, fall protection for persons working above four feet (general industry) or six feet (construction), confined space entry, lockout/ tagout, electrical work, PPE specific to each job, and hazard communication for job-specific hazards are among the many trainings required.

The level of sophistication required by an EHS manager to effectively perform his or her job has increased substantially. Consequently, smaller producers unable to afford trained, experienced EHS managers and large companies with many smaller facilities lacking an EHS manager at each site may face significant challenges.

For initial training and/or periodic retraining, the Occupational Safety and Health Administration's general industry regulations (29 CFR 1910) presently encompass 94 required safety topics. OSHA construction regulations (29 CFR 1926) include training requirements in approximately 48 safety areas. A free document — Training Requirements in OSHA Standards and Training Guidelines (OSHA 2254) — summarizing these requirements and guidelines is available from local OSHA offices.

According to the document, OSHA's training guidelines follow a model comprising multiple aspects:

• Determining if training is needed
• Identifying training needs
• Identifying goals and objectives
• Developing learning activities
• Conducting the training
• Evaluating program effectiveness
• Improving the program

TRAINING REQUIREMENTS

APPLICABLE TO THE CONCRETE PRODUCTS INDUSTRY