Night time in the switching yard: Listen to the train(ing) whistle whine

By Steve MacArthur, Hospital Safety Consultant

I suspect that, amongst all the other things that have been pounding on the metaphorical rooftops, you saw the updated guidance from OSHA relating to the Emergency Temporary Standard. I don’t know that there’s a great deal in play that would be particularly problematic, but I think the training requirements might be worth a little bit of work to ensure that the required elements are readily discernible to a regulatory surveyor. That said, I wouldn’t necessarily consider these “new” requirements, as with so many of the post-pandemic “requirements,” it’s all kind of based on what you would do if you were facing whatever event was coming down the pike. I really don’t think this is anything about which you should be concerned, but I figure it can’t hurt to get the list out and make sure that your program speaks eloquently to the individual components.

Here they are:

1910.502(n)

Training.

1910.502(n)(1)

The employer must ensure that each employee receives training, in a language and at a literacy level the employee understands, and so that the employee comprehends at least the following:

1910.502(n)(1)(i)

COVID–19, including how the disease is transmitted (including pre-symptomatic and asymptomatic transmission), the importance of hand hygiene to reduce the risk of spreading COVID–19 infections, ways to reduce the risk of spreading COVID–19 through the proper covering of the nose and mouth, the signs and symptoms of the disease, risk factors for severe illness, and when to seek medical attention;

1910.502(n)(1)(ii)

Employer-specific policies and procedures on patient screening and management;

1910.502(n)(1)(iii)

Tasks and situations in the workplace that could result in COVID–19 infection;

1910.502(n)(1)(iv)

Workplace-specific policies and procedures to prevent the spread of COVID–19 that are applicable to the employee’s duties (e.g., policies on Standard and Transmission-Based Precautions, physical distancing, physical barriers, ventilation, aerosol generating procedures);

1910.502(n)(1)(v)

Employer-specific multi-employer workplace agreements related to infection control policies and procedures, the use of common areas, and the use of shared equipment that affect employees at the workplace;

1910.502(n)(1)(vi)

Employer-specific policies and procedures for PPE worn to comply with this section, including:

1910.502(n)(1)(vi)(A)

When PPE is required for protection against COVID–19;

1910.502(n)(1)(vi)(B)

Limitations of PPE for protection against COVID–19;

1910.502(n)(1)(vi)(C)

How to properly put on, wear, and take off PPE;

1910.502(n)(1)(vi)(D)

How to properly care for, store, clean, maintain, and dispose of PPE; and

1910.502(n)(1)(vi)(E)

Any modifications to donning, doffing, cleaning, storage, maintenance, and disposal procedures needed to address COVID–19 when PPE is worn to address workplace hazards other than COVID–19;

1910.502(n)(1)(vii)

Workplace-specific policies and procedures for cleaning and disinfection;

1910.502(n)(1)(viii)

Employer-specific policies and procedures on health screening and medical management;

1910.502(n)(1)(ix)

Available sick leave policies, any COVID–19-related benefits to which the employee may be entitled under applicable federal, state, or local laws, and other supportive policies and practices (e.g., telework, flexible hours);

1910.502(n)(1)(x)

The identity of the safety coordinator(s) specified in the COVID–19 plan;

1910.502(n)(1)(xi)

The requirements of this section; and

1910.502(n)(1)(xii)

How the employee can obtain copies of this section and any employer specific policies and procedures developed under this section, including the employer’s written COVID–19 plan, if required.

Note to paragraph (n)(1). Employers may rely on training completed prior to the effective date of this section to the extent that it meets the relevant training requirements under this paragraph.

1910.502(n)(2)

The employer must ensure that each employee receives additional training whenever:

1910.502(n)(2)(i)

Changes occur that affect the employee’s risk of contracting COVID–19 at work (e.g., new job tasks);

1910.502(n)(2)(ii)

Policies or procedures are changed; or

1910.502(n)(2)(iii)

There is an indication that the employee has not retained the necessary understanding or skill.

1910.502(n)(3)

The employer must ensure that the training is overseen or conducted by a person knowledgeable in the covered subject matter as it relates to the employee’s job duties.

1910.502(n)(4)

The employer must ensure that the training provides an opportunity for interactive questions and answers with a person knowledgeable in the covered subject matter as it relates to the employee’s job duties.

Again, I feel pretty confident that these elements have been in place in most instances (PPE, risks associated with COVID, health screening, any changes to procedures, etc.) and (presumably) the effectiveness of the education process supported by data of COVID-related illnesses amongst the workforce. But it might be a good idea to “pull” these elements out as a syllabus (if that makes sense) to be able to walk a surveyor through the elements.

About the Author: Steve MacArthur is a safety consultant with The Greeley Company in Danvers, Mass. He brings more than 30 years of healthcare management and consulting experience to his work with hospitals, physician offices, and ambulatory care facilities across the country. He is the author of HCPro's Hospital Safety Director's Handbook and is contributing editor for Healthcare Safety Leader. Contact Steve at stevemacsafetyspace@gmail.com.