Many practice managers and employees cringe at the thought of conducting or attending safety training, the most dreaded meeting of the year. Among the excuses heard about why training doesn’t happen regularly and consistently are: we’re too busy; safety training is boring and nobody cares; “it” will never happen to us; getting the whole team together is too difficult; we don’t know how to do it; we don’t have the resources to train people.
Why Train?
Safety training is not optional. Every business, regardless of type, is required to train employees. The Occupational Safety and Health Administration is specific about when and how training must be done. OSHA standards require that employees get training so that work in their particular industry is performed safely and in a healthful way. Training must be conducted in a manner or language understandable to all employees. Lack of training and insufficient documentation are among the most common OSHA violations resulting in citations and fines.
What’s Required
An employee’s “right to know” was changed to “right to understand” with the 2012 adoption of the Globally Harmonized System of Classification and Labelling of Chemicals. Merely providing training and education isn’t enough. Employees must be aware of their rights and responsibilities.
OSHA requires the display of Poster 3165 (3167 in Spanish) in an area readily accessible to employees. This rule is in addition to any other state-required posters. States with state-specific regulations might have different versions. Posters can be obtained for free from your state labor board or directly from OSHA at bit.ly/3wO0KNx.
Once the training is done, you must be able to prove that employees understand the material, subject matter and all other information. This threshold can be met by requiring a written quiz.
When to Train
In general, conduct safety training at defined intervals and under specific circumstances. At a minimum:
At the time of hire and before the employee is exposed to potential workplace hazards.
- Annually.
- As safety standards change.
- Additional training opportunities might arise because of:
- Changes within the veterinary practice. An example is after a remodel, installation of new equipment or the addition of a treatment protocol such as chemotherapy. Assess the potential new hazard and provide specific training.
- Incidents or trends within the practice. An example might be additional training on animal handling and restraint after a spike in animal-related injuries.
Where to Begin
Although industry-specific hazards need addressing, your training will be specific to your clinic and services. Start with a facility hazard assessment. What are the dangers and risks of injury? Next, analyze job hazards. What are the risks of specific jobs and tasks? Use your individual safety plans as a springboard and focus on injuries or common hazards particular to the veterinary industry, such as zoonosis, radiation and bites.
The training will include identifying hazards and how to prevent injuries or illnesses.
How to Train
The key to conducting practical training sessions is a plan and team involvement. Your safety coordinator and safety committee should make sure that all required training happens.
The initial safety training for new employees is arguably the most comprehensive and time-consuming. Many practices have invested time and resources in developing comprehensive videos specific to the clinic. New employees must watch the videos, and a quiz should be given afterward to ensure that everyone understands the material. Be creative with your training by using handouts, props, photos, live demonstrations, a review of incident reports, and quizzes and prizes.
The more creative, interactive and participatory your training, the more impactful it will be.
Document the Training
From a regulatory standpoint, undocumented safety training did not happen. You must have a record of every session regardless of whether it involved a new hire or a group. Keep the documentation up to date and easily accessible. Document the training of new hires in each employee’s personnel file. Group training documentation can be kept in your safety training file. The documentation should include:
- Training date.
- Employee name. Use a sign-in sheet during group training.
- Training subject.
- Training methods, such as an in-person meeting, videos, webinars or online modules.
- The agenda, topic and resources provided if the training occurred during your monthly team meeting.
Keep training records for three years. Most practices retain individual training records as long as the person is employed.
Reporting Requirements
In addition to documenting all training, work-related injuries and illnesses must be recorded and, in some instances, reported. OSHA’s 300 series forms — find them at bit.ly/3tfwitv — are designed to record all incidents correctly. The series includes:
- Form 300: A log of work-related injuries and illnesses.
- Form 300A: A summary of injuries and illnesses that occurred during the calendar year. It must be posted in a conspicuous area of the workplace from Feb. 1 to April 30 of the following year, even if the record is spotless.
- Form 301: A document used to record individual injuries and illnesses. Omit names if privacy concerns exist. You must use this form or an equivalent, such as reports recognized by some state workers’ compensation programs or insurance companies. As you fill in Form 301, remember to update your 300 log.
Maintain all these forms for five years.
In addition, the online Injury Tracking Application (ITA) was introduced in January 2019. OSHA’s final rule requires employers in certain industries to submit Form 300A electronically. Learn more at bit.ly/3d290kR.
Leadership is the most critical factor in achieving an effective safety and health program. Animals are unpredictable and anything can happen in a veterinary setting. Be aware of potential dangers, provide necessary training and do everything you can to ensure a safe work environment.
MORE RESOURCES
You can find additional safety and training information at:
- bit.ly/3uDPP6P: “Training Requirements in OSHA Standards”
- safetyvet.com: SafetyVet’s Solutions for the Veterinary Professions
- bit.ly/34efBE2: Patterson University’s “OSHA and Safety Management” course