| Last time we discussed the various training requirements likely to be applicable to print shop employees by regulation. Environmental and safety training is always specific to an employee’s job responsibilities. So a press operator might need Hazcom training while a front office receptionist in the front office may not need it. You can also authorize employees to use a fire extinguisher or be a First Aid Responder. In those instances, authorized employees get only the additional training they need.
To assist you in making that determination, I am providing two tables of training needs by job responsibility. I reference the Traintheprinter modules for environmental and safety training commonly identified in lithographic printing operations. However, you could apply the regulatory training to other print processes. Table 1 lists training for office employees and Table 2 for production employees.
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TABLE 1
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Administrators
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Graphic Design
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General Office Employees
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Accounting
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Newsroom1
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General Safety Overview2
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Yes
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Yes
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Yes
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Yes
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Yes
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Fire Extinguishers3
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Yes
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Yes
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Yes
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Yes
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Yes
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Hazcom
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Yes for Production Administrators
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Yes, if works in Prepress
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No
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No
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No
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Lockout/Tagout
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Yes for Production Administrators
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Yes, if works in Prepress
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No
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No
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No
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Mail Handling Safety4
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Optional
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.
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Optional
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.
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.
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| Workplace Violence5 |
Optional
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Optional
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Optional
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Optional
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Optional
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Notes:
1 For newspaper operations. Hazcom training is required in the event that reporters are required to cover chemical release incidents.
2 General Safety Overview covers basic safety and emergency action issues and a "lite" version of Hazcom and Lockout/Tagout for office employees.
3 Only required for employees authorized to use fire extinguishers.
4 Not required by OSHA. Recommended for employees involved with receiving and sorting mail and packages.
5 Workplace violence training is currently not required by OSHA, but it is recommended for all employees.
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TABLE 2
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Prepress
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Press
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Mailroom & Bindery
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Warehouse
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General Safety Overview1
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Yes
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Yes
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No
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Yes
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Mail Handling Safety2
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No
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No
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No
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Optional
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Hazcom
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Yes
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Yes
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No
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Yes
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PPE
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Yes
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Yes
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Depends on responsibility
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Depends on responsibility
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Lockout/Tagout3
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Yes
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Yes
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No
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No
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Annual Hazardous Waste
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No
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Yes
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No
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Yes
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Annual Hearing Protection4
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No
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Yes
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Yes
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No
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Triennial DOT Hazmat
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Yes
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Yes
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No
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Yes
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Annual Fire Extinguishers6
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Yes
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Yes |
Yes
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Yes
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Mailroom Safety7
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No
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No
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Yes
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No
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Workplace Violence7
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Optional
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Optional
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Optional
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Optional
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Notes:
1 General Safety Overview covers basic safety and emergency action issues and a "lite" version of Hazcom and Lockout/Tagout for office employees.
2 Not required by OSHA. Recommended for employees involved with receiving and sorting mail and packages.
3 Authorized employees must get additional training on specific lockout/Tagout procedures for which they are responsible.
4 Only if hearing protection is mandatory under the OSHA Occupational Noise Rule.
5 Only if involved with receiving hazardous materials (inks, solvents, etc) or shipping hazardous waste, universal waste and waste oil.
6 Only required for employees authorized to use fire extinguishers.
7 A single training module that covers basic environmental and safety issues and a "lite" version of Hazcom and Lockout/Tagout for Mailroom/Bindery employees.
8 Workplace violence training is currently not required by OSHA, but it is recommended for all employees.
To better understand your own employee training needs, I recommend you develop a similar table specific to your operations. Once done, you can integrate environmental and safety training into your new hire orientation program.
Remember all safety training must be provided BEFORE an employee starts his job. So doing all your safety training for new and existing employees once a year may not be compliant. That’s why training a new hire is the preferred method of compliance. However, there are two exemptions. For hazardous waste training, you have up to six months if they are supervised in the interim. For DOT hazmat, you have 90 days if supervised.
For your existing employees, you can establish a monthly or quarterly training effort by topic. For example, do Hazcom training in January, Lockout/Tagout in February and so on. Employees can set their own time to take the training as long as it gets done before month end. This reduces management burden coordinating training times particularly if you are doing classroom training now. And if you use Traintheprinter, you get email acknowledgements every time an employee completes a module, allowing you to track the stragglers.
Next – We’ll talk about written compliance documents.
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