The foundation of workplace safety is an organization’s ability to create a culture where both company leadership and employees have a vested interest in a workplace ethos that values worker health and safety. This all-important culture serves as the context for all aspects of workplace safety, and undergirds these efforts. It also serves as a springboard for investigating and initiating the processes, systems, and documentation required for workplace safety compliance.
An often-overlooked reality for many in our industry is that workplace safety involves much more than just protecting our employees at height; many other tasks they undertake during a workday can be potentially hazardous.
And whether we are a commercial aerial adventure operation, a traditional challenge course program at a camp or retreat center, or a course installation company, our businesses are subject to the laws and codes governing workplace health and safety, as any other business or industry is. We are not exempt from these requirements just because what we do is, from our perspective, unique or different.
In the United States, the Occupational Health and Safety Administration (OSHA) writes standards and enforces laws related to workplace safety. The two standards most relevant to our businesses are 1910, the general industry standard; and the construction standard, 1926. These documents detail the requirements for what employers must provide for their employees to create a generally safe and healthy work environment.
And though these standards outline specific details on many aspects of workplace safety, the one critical and all-encompassing requirement in all workplace safety regulations is the necessity of proper employee training and, by extension, the associated record-keeping and reporting that documents the training.
SCOPE OF EMPLOYEE TRAINING
Most course operators are well-versed in the importance of staff training when preparing facilitators or guides to move about their courses properly and operate according to approved local operating procedures when leading a tour or running a program. For most, these concepts are well understood and are handled with purpose and intentionality.
However, when considered in the greater context of overall workplace safety, it’s clear there are many other areas to address besides staff training for operations. To list all the specific training requirements outlined in OSHA 1910 and 1926 is, of course, far beyond the scope of this article. However, the General Duty clause, found in section 5(a)(1) of the Occupational Safety and Health (OSH) Act provides some simple, straightforward guidance. It states that each employer must “furnish … a place of employment which [is]free from recognized hazards that are causing or are likely to cause death or serious physical harm” to employees.
Therefore, compliance with this requirement means that employers must:
1. Be aware of the hazards their employees are subject to.
2. Clearly communicate those hazards.
3. Provide training for employees as part of a system for mitigating those hazards.
Put succinctly, the General Duty clause obligates employers to take whatever steps are necessary to reduce employee exposure to hazards, regardless of whether or not there is a written standard that addresses that specific hazard.
We identify the hazards in every area of our business by doing a proper hazard assessment (see “Hazards Ahead,” Adventure Park Insider, Winter 2023, or the video on Hazard Assessment in the Challenge Course Pro Tips! Workplace Safety Series).
So, what training do you need to provide for your employees to comply with the laws governing workplace safety? If an employee is required to undertake a task or activity, there is a duty to ensure that person has the proper training and information to do that work safely. This training must cover the hazards associated with the employee’s activities and how to mitigate them effectively.
This often includes activities an aerial adventure company accustomed to focusing primarily on work-at-height safety may overlook. Hence the importance of doing a proper hazard assessment.
Consider: Do employees operate a vehicle or machinery? Do they spray chemicals like herbicides and pesticides on trails or areas around structures? Do they use compressed gas such as propane or MAP gas in rope-cutting procedures? Do they use power tools for doing construction or repair work?
If so, in each case, employers are required to provide training in:
1. The proper way to execute the work.
2. The appropriate use of any necessary protective equipment and clothing.
3. How to recognize and report unsafe conditions.
4. What to do in the event of an emergency.
DOCUMENTATION AND REPORTING
Workplace safety standards also include requirements for training documentation and for reporting workplace injuries and fatalities. Some of the categories include:
• Use of personal protective equipment (PPE training documentation)
• Hazardous waste operations (HAZWOPER training documentation)
• Forklift training documentation
• Process safety management
• Respiratory protection
• Permit-required confined spaces
• Powered industrial trucks
• Lockout/tag out
Same as it is with training, documentation should not be limited to just the items specifically called out in the standard.
What should be documented? If you’re wondering what trainings need to be documented, consider the first two questions that an OSHA inspector (or other workplace safety inspector if you operate outside the U.S.) is likely to ask while investigating an employee injury or fatality at your workplace: “Was this employee properly trained in the work they were doing when this incident occurred?” and, “Can I see that documentation?”
In February, while leading a workplace safety workshop, we were discussing the subject of documentation. And an attendee made a pithy but poignant statement that drives home an important point: “If it’s not on paper, it’s vapor.”
In other words: if you do it, document it.
TRAINING SCHEDULING AND RECORD-KEEPING
One of the biggest challenges in the hectic pace of business is staying on top of training schedules, record-keeping for that training, and the logistics of keeping things current, especially if you operate a business where employees are regularly at different locations. In those circumstances, it can be difficult to maintain up-to-date paper records of employee training. Thankfully, we have tools at our disposal that can help us navigate those challenges.
Digital tools. First, schedule the necessary training at the beginning of the year, place it on a cloud-based calendar, and ensure all relevant team members have access. Set reminders for a week or more ahead of the scheduled training so that everyone is alerted.
Second, consider moving from paper documentation to a centralized cloud-based system. This move allows all employee training documents to live in the same location, and be easily updated and viewed from anywhere with internet access. Many options exist for this purpose, but since many companies already use Google Workspace for email, they already have access to Drive, Forms, and Docs, which are great tools for centralizing training documentation.
And finally, if your organization is particularly complex, a web-based learning management system designed to schedule, track, and document training may be a great option. These systems are usually quite robust. They can also include or link to online training modules, so when it’s time for an employee to update training, they get a notification and a link to that training resource. A quick web search will yield a long list of companies offering these services with various features and price points.
Whether you use a web service or a notebook, be diligent about providing the training your employees need and documenting that training properly to demonstrate due diligence and a continued commitment to having a culture of safety within your organization.
For more information on workplace safety, watch the Workplace Safety video series at adventureparkinsider.com/challenge-course-pro-tips/.
