Has your district provided staff with health and safety training?

Published in the February 2016 NJEA Review

by Adrienne Markowitz and Eileen Senn

HnS Feb 2016As the school year reaches the halfway mark, it is the perfect time for local associations to make sure their school districts have provided accurate, credible, clear, and practical health and safety training. Such training is necessary for school staff to have the skills and knowledge required to safely do their work.

Mandatory training requirements are found in Public Employee Occupational Safety and Health (PEOSH) standards and New Jersey Department of Education regulations. These requirements reflect PEOSH’s belief that training is an essential part of every employer’s safety and health program.

 Local associations should work with their UniServ field representatives to ensure that all required training has been provided and paid for by school districts. Locals should tell districts about the two excellent new OSHA publications on training listed under “For more information” on the next page.

Training is an investment that will pay back again and again in fewer injuries and illnesses, better morale, lower insurance premiums and more. If necessary, locals can lodge complaints with PEOSH against districts that shirk their training responsibilities. But remember that PEOSH is most effective when used as part of a local plan for health and safety that includes member education, a health and safety committee, active rank and file involvement and contract enforcement.

Training in reporting violence and vandalism

Boards of education are required by a public school safety law, NJSA 8A:17-46, to provide ongoing staff training, in cooperation with the Department of Education, in fulfilling violence and vandalism reporting requirements. Local associations should not only make sure this training takes place but also negotiate to expand the training to also cover violence prevention, how to deal with student disruptions and staff self-protection.

Training required by PEOSH

Over one hundred PEOSH standards require employers to provide exposed workers training covering the requirements of the standard, how to recognize the hazard, the nature of the hazard and methods of protective control.

The training must usually be provided at the time of initial assignment and periodically thereafter. Some standards require records of training to be kept, training to be appropriate in educational level, literacy, and language, to be at no cost to employees, and during work hours.

HnS Feb 2016Examples of groups of school employees who may be covered under specific standards relevant in the school setting include:

Portable fire extinguishers: all staff (1910.157): Where the employer has provided portable fire extinguishers for employee use in the workplace, the employer shall also provide an educational program to familiarize employees with the general principles of fire extinguisher use and the hazards involved with incipient stage firefighting.

Hazard communication: custodians, art, science, and vo-tech teachers (N.J.A.C. 12:100-7): Effective training by a technically qualified instructor must be provided to all employees exposed to hazardous chemicals upon initial assignment or introduction of a new hazard, with refresher training every two years.

Occupational exposure to hazardous chemicals in laboratories: science teachers (1910.1450): Employees shall be apprised of the hazards of chemicals present in their work areas upon initial assignment and prior to assignments involving new exposure situations. The training shall include the applicable details of the employer’s written Chemical Hazard Plan.

Lead: all staff (1910.1025):
Any school built before 1978 should be presumed to have been painted with lead paint inside. If the paint is peeling or chipping, there will be some airborne lead exposure from the dust this creates. Employees who may have airborne exposure at any level must be informed of the content of Appendices A (lead data sheet) and B (summary of the lead standard).

Lead in construction: custodians (1926.62): Employees exposed over the action level on any day or for whom the possibility of skin or eye irritation exists must be trained upon initial assignment and annually.

Bloodborne pathogens: nurses and first aid providers (1910.1030): Training by a knowledgeable person must be provided at time of initial assignment to tasks where exposure may take place and annually thereafter. Information on actions to take and persons to contact in an emergency involving blood or other potentially infectious material must be provided.

Control of hazardous energy (lockout/tagout): Custodians and vo-tech teachers (1910.147): The employer shall provide training to ensure that the purpose and function of the energy control program are understood by employees. Retraining shall be provided whenever there is a change in job assignments, a change in machines, equipment or processes that present a new hazard, or when there is a change in the energy control procedure.

Asbestos in construction: custodians (1926.1101): Employees who may be exposed over the exposure limit or who perform Class I though IV asbestos operations must be trained upon initial exposure and at least annually thereafter. Class I is removal of thermal insulation. Class II is removal of asbestos-containing wallboard, floor tile and sheeting, roofing and siding shingles, and construction mastics. Class III is repair and maintenance operations, where asbestos is likely to be disturbed. Class IV is maintenance and custodial activities during which employees contact, but do not disturb, asbestos. Class IV activities also include cleaning up dust, waste and debris resulting from Class I, II, and III activities.  

For more information

NJEA Health and Safety Manual
Training and Education, pages 16 and 17
When to use PEOSH, pages 40 to 44
http://bit.ly/usepeosh

Training Requirements in OSHA Standards
OSHA Publication 2254-09R, 2015, 256 pages
www.osha.gov/Publications/osha2254.pdf

Resource for Development and Delivery of Training to Workers
OSHA Publication 3824-08, 2015, 44 pages
www.osha.gov/Publications/osha3824.pdf

Adrienne Markowitz holds a Master of Science in Industrial Hygiene from Hunter College, City University of New York. Eileen Senn holds a Master of Science in Occupational Health from Temple University in Philadelphia. They are consultants with the New Jersey Work Environment Council, which is a frequent partner with NJEA on school health and safety concerns.

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