Working at Heights - Workplace Safety North · Working at Heights •Following this tragedy, the...
Transcript of Working at Heights - Workplace Safety North · Working at Heights •Following this tragedy, the...
Working at Heights An Assessor Perspective
Jerry Traer, CRSP
Program/Training Specialist
Workplace Safety North
Working at Heights
• In December 2009, four construction workers died and another was seriously injured in a workplace incident in Toronto.
– This incident had high visibility with the media in the Toronto area and outside Ontario
– Ministry of Labour prosecuted Metron and Swing n’ Skaff
– Program Manager from Metron was sentenced to 3 ½ years in jail
Working at Heights
• Following this tragedy, the Minister of Labour appointed an Expert Advisory Panel to review Ontario’s occupational health and safety system.
– Recommendation 17 of 46
• The Ministry of Labour and new prevention organization should develop mandatory fall protection training for workers working at heights as a priority and consult with stakeholders to determine additional high-hazard activities that should be subject to mandatory training for workers
Working at Heights
• December 2014
– Working at Heights Training Program/Provider Standard was officially released
– HSPACU (Health and Safety Program Administration and Certification Unit) was formed – Assessors/Administration
• January 2015
– MOL started to accept applications
• April 1, 2015
– Training after this date by MOL Approved Training Providers only
– Training before this date was good until 2017
My WAH Background
• December 2014
– Seconded to the MOL to be a Training Standards Assessor
– Two weeks of training provided by the MOL on both Standards
• January 2015
– Worked through an application with all of the Assessors to try to have some consistency with the WAH approval process
• March 2015
– Conducted my first field assessment
The Typical WAH Process
• Triage
– Documentation sent into the MOL by the Training Provider
• Desk Assessment
– Complete review of all the training material
• Field Assessment
– Attendance at a mock program
• Recommendation for Approval by CPO
• CPO Approval
• 10 week average timeline/6 weeks listed in the guidelines for filling out the application
Triage
• Fairly quick turnaround if all documentation was in order, sent to desk assessment
• If documentation was not in order, missing components, sent back to the training provider for rectifying
• Timelines to correct could be days to weeks to months depending on the deficiencies
• Training Provider could rescind their application at this point if the work was going to be excessive
Desk Assessment
• Complete review of all of the material including;
– Participant material/Leaders material
– Powerpoint slides/videos
– Learner evaluation components at various stages of the program
– Continuous improvement and quality assurance
• Assessors were guided by resource documents/spreadsheets outlining all of the requirement in the program/provider standard
Desk Assessment
• Items not dealt with appropriately were listed as deficiencies
• Training Providers had 45 business days to rectify these deficiencies – more time was given if the training provider was working on correcting deficiencies
• Deficiencies ranged from a low of four deficiencies to a high of eighty deficiencies.
• Deficiency Action Plans outlining the corrective actions were sent back to the MOL and the assessor
Field Assessment
• Training providers, once desk approved, would move onto the field assessment
• Demonstration of the instructor to follow the program and to show their advanced knowledge of the material and fall protection
• Deficiencies for the field assessment ranged from no deficiencies to upwards to twenty deficiencies
• DAPs either required some minor changes and then resubmitted for approval or a second field assessment if deficiencies were major
Field Assessment
• Focus was to follow the desk assessment approved material, no deviations
• Demonstration exercises – equipment inspection, donning/doffing harness and 100% tie off were to be completed successfully, no deviations
• Evaluation exercise (test) to be completed as well. Demonstrating that the participants were given the tools to successfully complete the evaluation/test
Recommendations for and CPO Approval
• Recommendation for CPO Approval was sent to Manager of HSPACU for approval/rejection
• CPO reviewed and approved the WAH programs and WAH providers
• Instructors were not approved. Onus falls onto the training provider to ensure instructors follow the requirements of both the WAH program and provider standards
WAH At This Point
• 85 Approved Training Providers
– Additional 166 training providers/individuals under IHSA
• 14 Rejected Training Providers
• 18 in the queue being assessed right now
Personally
• 14 Approved Training Providers
• 3 In House Training Providers
• 1 Rejected Training Provider
Purchased Programs
• As mentioned in a previous slide, IHSA has 166 external consultants that run IHSA material under IHSA approval process
• Another option is for training providers to sell their MOL approved program to other training providers
• Purchased program training providers would still have to submit the application to the MOL and have a field assessment completed.
Purchased Programs
• This proved to be the most difficult part as the training providers did not understand that the process had to be followed
– Most didn’t realize that a field assessment had to be completed
– Majority of rejections came from the purchased programs
• Purchased programs did not have the same process, no desk assessment as long as the material stayed the same
Most Common Deficiencies at Desk Assessment
Training Program Standard
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5 7.2 9.1.19.1.29.1.39.2.19.2.29.2.3 10.2
Design – Section 5
• Compliance with adult learning principles:
• Language and literacy level appropriate for the learners.
• Content accurate, current, and all legal and technical information is referenced and verified.
• Learner materials follow principles of instructional writing and good graphic design
Personal Fall Protection Equipment – Section 9.2.2
• Discuss the limitations and the appropriate application of travel restraint, fall restricting and fall arrest systems;
• Discuss the fundamental components of travel restraint, fall restricting and fall arrest systems;
• Determine the fall distance to prevent a worker from striking the ground or an object below;
• Define and explain the effects on the human body of “bottoming out”, the pendulum effect, and suspension trauma;
Personal Fall Protection Equipment – Section 9.2.2
• Demonstrate an ability to inspect and identify deficiencies in industry-standard personal fall arrest equipment;
• Demonstrate how to appropriately "don" and "doff" (i.e. put on and take off) industry-standard personal fall arrest equipment, including harness and lanyard;
• Explain methods to maintain tie-off at all times to an anchor point when changing anchor points
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Most Common Deficiencies at Field Assessment
Training Program Standard
Original Program
Purchased Program
Learner Evaluation – Section 10.1
• There must be a written test either at the end of each module or at the end of the whole training program
• The purpose of the written test is to verify that the key concepts have been understood by learner. The learner must obtain a minimum of 75% in order to successfully complete the training program
• After a learner has successfully completed the test, the evaluator must review incorrect answers with the learner in order for him or her to successfully complete the training program
Learner Evaluation – Section 10.2
• Learning outcomes requiring demonstration (sections 9.2.2(h), 9.2.2(i), 9.2.2(l)) must be performed satisfactorily in order to successfully complete the Working at Heights Practical module
• Purchased programs in many assessments did not follow the program with these demonstration exercises
Most Common Deficiencies at Field Assessment
Training Provider Standard
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Original Program
Purchased Program
Instructor Qualifications – Section 4.1
• Technical knowledge and experience in health and safety
• Adult education delivery knowledge and experience
• Knowledge of the MOL approved program
• Advanced knowledge in the correct use and application of equipment referred to and used in the MOL approved Working at Heights training program
– Several purchased programs were rejected
My Experiences During Field Assessments
• 2 dogs in attendance at field
• Conducted one field assessment in a training providers kitchen at their home, demonstration exercises conducted in their garage
• 1 training provider was required to conduct a second field assessment
Oddities of the Process
• One program developer was crying after an unsuccessful first field assessment
• One training provider conducted the training in a garage during a rainstorm
• Material submitted in one program had trainees standing on a chair with their harness/lanyard attached at an anchor point, instructor was to kick the chair out so the trainee experienced a real life fall, subsequently the assessor did not allow this to happen
Improvements to the Process
• Early in the process, training providers were allowed to review their material if it looked like they were going to have many deficiencies
– Assessors provide the training providers with a document qualification form and letter
– Saved time for the assessor, who could discuss with the training provider any deficiencies noted during a cursory review of the material
– Training providers went back to the drawing board and got it right from the onset
Improvement to the Process
• WAH Application form was 43 pages.
– Took training provides several weeks to complete
• JHSC Application form was reduces significantly – 13 pages
• Specific forms developed by HSPACU to deal with desk and field assessments
Next Steps
• The use of program and provider standards will continue to be used by the MOL for mandatory training
• MOL may develop the material that everyone will follow
• Several mandatory programs are either in material development/approval phase (WAH/JHSC), design phase (CHSAT), concept phase (HSR)
WSN Approach
• WSN will be following the IHSA model with regards to external trainers conducting Working at Heights training under the umbrella of Workplace Safety North
• Individuals and/or organizations would apply to become external training providers under WSN’s approval status
Instructor Qualifications and Delivery Expectation
• Will require an individual instructor qualifications application to ensure each instructor has the necessary technical, adult education and knowledge requirements as outlined in the standard
• Will require instructor delivery expectations, learning environment, code of ethics, equipment requirements as part of being an external training provider.
• Contact WSN for more information
Finally
• Want to thank the management group at WSN for allowing me the opportunity to participate in this process
– Learned a lot about Working at Heights
– Saw a lot of variety in program development skills
• Want to also thank the Ministry of Labour Prevention Office, our Chief Prevention Officer and Jules Arntz-Gray (Manager of HSPACU unit) for giving me the opportunity to do this