In this episode, Sheldon goes over the nuances of becoming an Authorized OSHA outreach trainer, the process for receving your authorization, special conditions for being an authorized trainer, and more.
Keywords: OSHA, OSHA Compliance, Sheldon, Primus, Sheldon Primus, 10 Hour Construction, 10 Hour General Industry, 30 Hour General Industry, 30 Hour Construction, Safety, Health, EHS, Job hazard analysis, OSHA jurisdiction, Puerto Rico, US Virgin Island, Guam, Public Speaking, Public Speaking, Training, Safety Training, EHS Training, US, Canada, Nigeria, Africa
[00:00:00] : mhm. This episode is powered by safety FM mm. Welcome to the safety consultant podcast. I'm your host show. The premise this podcast, I teach you the business of being a safety consultant. Yeah. And this is the way that you could actually ask me questions as well. And I could be your consultant, get the americans safety consultant. So today we're actually going to go over something that I've long said is one of the main ways if you could uh either introduce yourselves to a company or a way for you to pretty much Have some income through training. So this way is by the OSHA outreach programs, the 10 and 30 our outreach. So I'm going to spend this episode kind of going over the program requirements themselves. That is as of, Let's see, it's effective April one, and as this day of recording in July, It's the 3rd 2021. It's still effective. So this is the most recent revision for the training requirements. So we're gonna kind of go over some of the dues and don't on this one as far as requirements. And then also the significance that this program can have for you as a safety consultant. So let's just hang in there and we're gonna go ahead and learn what we could do as far as being an OSHA outreach trainer. Those of you that are outside of the US OSHA outreach training is not available for you unless there's like a really, really mitigating circumstances on that one. Uh, so therefore you may have to find an equivalent in your country. However many people like the the OSHA model in different countries, so therefore they're probably going to be things in here that you guys could use as well. Weeks. All right, well, without any further do, since it's just me, let's go ahead and let's get into this one. All right. So, the training requirements from OSHA, and this is truly if you want to be an OSHA trainer. So there's many people who can be OSHA train authorized trainer. So one of the first things we're gonna just briefly talk about is who can be an authorized trainer as well as you know, just the program requirements. Right? So in order to be an authorized trainer, it's actually a process. Right? So the process itself is several fold. But before we get to that, let's go and let me tell you The areas that you could get your training in. So, OSHA has 10 and 30 hour classes available in construction, general industry, maritime and Disaster site workers. So, those industries, those activities, They can get OSHA 10 and 30 hour training To 10 and 30 hour. OSHA says that these trainings are not compliance training, their awareness training, meaning you can't offer this service and then go ahead and say that this is going to meet OSHA's regulation for excellence because that's not allowed The 10 and 30 hours when you're quoting this or you're going to start using this. That's one of the things that you should not go ahead and try to add in there saying, Oh yeah, well not only am I going to teach you the 10 and 30 hour and you're going to get your OSHA cards and the Department of Labor cards, but it's also going to meet your OSHA requirements for lock out, tag out, it's going to meet your OSHA requirements for electrical safety training. No, actually plainly says that this isn't for compliance, It's really just for awareness factors. So now that, you know, the four areas that OSHA is going to be looking at, I'm gonna tell you just a brief process on uh what you need to do to be an authorized trainer. So first you're going to have to pick your poison if you will, meaning, oh I want general industry or I have more experience in general industry, have more experience in construction, maritime disaster site worker. So once you have that, then you're going to have to take the first class and I'll just do construction. Uh, just so we'll help you out. So the first class will be the construction 510 and its ocean numbered class. So you have to do that one first and then you have to take the OSHA 500. So once you do the OSHA 500, Then at that point you'll be able to to do the, well that is the train. The trainer won the 500 number series when you're done with that and you successfully complete that one. Then what that means is now you can be an authorized ocean instructor prices change. So I can't really give you the prices to do this, but I would kind of bank on At least $500 us dollars to do both courses. In some cases it will be more, but right around there it's going to be probably what you're looking for. I remember my first on the 700. So it's a possibility that you may be as high as that depending on who you choose to be your OSHA outreach person. So there are OSHA outreach training programs and you don't have to go to one that's closest to you. You can go to one anywhere, but you just basically have to pick one so you can't do several. So that's the, the ground rules with that one. So let's go over the changes that this um 2016 version of doing the actual OSHA outreach and how to do and everything else. And then when you become authorized, what you need to do with that, there's a whole bunch of rules. So you really want to go in on the OSHA dot gov website. You want to just look for 10 and 30 hour training. And the document heading that you're going to be looking for is OSHA training program requirements. So if you're on that page then, or I should say in that document, then we are together on the same page of where we need to be. So when this thing first came out or the changes first happened, one of the big things that was affected a lot of people is OSHA stumped a grace period for trainers. They used to allow if you forgot your uh update your training, that you can go ahead, ask for a grace period and then Uh, well actually you don't even need to ask it was there, you could have a grace period up to, I think it was 90 days of very call right to get your act together, get your paperwork in and you actually need to take an updated class. So for construction it would be the uh huh 502 or 503 I think it is one of those classes and something, I can't remember right now, but really what it is, it's an um construction update class and you have to do that every three years. So if you've missed your time period from when you're you expire, that's it, you're gonna have to start over and go through the whole process. Pay all that money again for, for those courses that you needed to take. So that one's a little tough. But it's in the rules if you do let your license or your authorization expires shouldn't say license authorization then you cannot give a class. Obviously they don't want you doing classes where you can have alcohol served And they really want to make sure for every two consecutive hours of training there is a 10 minute break and you must do that. So that's a big one for the rules. You can only have training For 7.5 hours but you could do administrative work and other things and your max time would be 10 hours consecutive. So other than that. Ah Well generally what you're going to be doing at that point is you're going to like break it up where you have your brakes, administrative time, everything else. But you've got to keep watching your clock and just make sure that you don't go over, especially on the, the break time. Uh, it's what will happen is when you're writing at your hours because you need to verify your hours when you submit your information to make sure that the people that took your class will get their certificate or get their OSHA cards. So you got to do this right? So in those cases you want to really make sure that you're going to log your own time as your, uh, conducting your class. So that's a good thing to remember. All right. So I'm going to go through some of the headings and some of the things that you'll find in this document. It's a 38 page document. But this one is again for the training requirements. So first they tell you that you have to be, you have to see the words authorized trainer as opposed to certify. Because OSHA doesn't certify anyone, even though you may hear often Someone say something like, oh yeah, I have my OSHA certification in 10 or 30 hour training. You are authorized to do these trainings. So it's a big difference to OSHA when you're actually going to be going through your, your training to become an authorized Ocean Inspector, they will on the second class that the preliminary class that you need to do the pre records at class, they won't really tell you anything except just having you learn the lessons that you need to learn for that class. But when you do the trainer class to train the trainer ones, they will give you some hints and material and other things that you're gonna need to help you facilitate your class. So that's gonna be good. So even though she is telling you things in the program, guidance, your ocean, your OSHA training Institute, they're actually going to give you some resources for this as well. So let's get into what your, your actual, um, Rules are. And I'm only going to can't read the whole document obviously because there's 38 pages. But what I will do is just point out some of the things that, that are frequent that I, I know that man, I see this thing all the time happening. So one of the things that I do see is that for, let's say inappropriate behavior for, for instructors, maybe even lack of professionalism. Um, I don't see the lack of professionalism meaning the instructor is doing something that they think is just ingest. However you could see everyone cringe either in the room or in an office or wherever they're saying, Whatever they're saying, that would be inappropriate behavior or lack of professionalism and it could lose you your actual OSHA authorization to teach. So you've got to be careful for that. If the classroom setting that you choose to have, uh, your actual training is not suitable for learning, such as in a bar or residents or something else that in itself is going to invalidate your training. So that's something else to look for. If you have ever been convicted of a felony, you may be subject to and I'm going to read this corrective action including uh suspension or rift revocation, meaning they're going to revoke your license, revoke your authorization. See even I have to keep saying not licensed. It is authorizations, so it's possible that they can't do that as well. And this is prior to formal felony convictions. Prior to give me felony convictions does not automatically preclude a prospect trainer from attending a training course or seeking individual training status back if you are actually uh, training and they get convicted of something like that, then your authorization is in jeopardy. If you don't handle your payments right for any kind of tuition reimbursement or anything in a professional manner, this can also affect you. So let's talk about this one real quick. So I'm going to read this one for you says. This includes failing to reimburse full course tuition and fees within five business days of canceling a class or if a trainer reschedules to cancel the class, Excuse me? Uh, if the trainer reschedules the cancel class, failing to reimburse full course tuition and fees to each student, that does not affirmatively agree within 10 business days of the class cancellation to attend the rescheduled class. So that means you can lose your authorization if you don't handle the money, right? So you can't even handle the money right in order for you to keep everything up. You can't double schedule and you definitely need to make sure that you are monitoring your actual time. I'm going to see. You don't run again because oh, should really really strict on this one. All right. So let's also go through some of the things that are low hanging fruit for OSHA. I've done I've actually done uh an audit of a class before for what's called the O. T. E. I See or Otc. Excuse me. Which is OSHA training? Uh Yeah. Russia Training Institute Education Center Man. So many acronyms and safety. I just got to get all these acronyms. But that is it. So with your O. T. I. S. And that's just short for you know, OSHA Training Institute when you do have those. Yeah, they really need you to to to make sure everyone is in attendance from Moment 1 2 The last sentence, the goodbyes shaking of hands. They cannot miss anything or else they're going to have to make up that work later on the contact hours that they're calling student contact hours. Here's what it includes. So there's some people that want to get really let's say creative might be the best way to put it with contact hours. So let's go ahead and I'll read this one for you. Student contact hours refer to time spent covering course content. Student contact hours does not include breaks for meals or other breaks or time spent on administrative matters such as taking attendance and administrating optional tests. And here you go optional test. They they have that word in several different ways. You don't have to have a test for doing your OSHA 10 and thirties. So they do say optional. However, That doesn't count towards the time. So let's say you're doing a 10-hour class and you're literally writing down 10 hours on your form because you do have to do a form to submit and you allocator minutes. If you allocate a 10 hour class and it's exactly at 10 hours, then that means you're not you're not putting in any time for breaks, you're not putting in any time for uh any kind of administrative. So generally what you would do, let's say you're holding a class and you're doing it um 8 - 3 30. So at this point Let's see, 9, 11, 12, that's four hours one, two, three is going to give you your seven hours and then 3.5, meaning 3 30 is going to give you your 7.5 hours of contact time. Okay? So you want to make sure you guys are following this one? So let's say you have 7.5 hours of contact time in there, you would have some breaks, you would have the lunch, you may have some administrative time for doing roll call. That means you when you submit your time for that day, your start time would be a But you could actually extend your end time can't be any longer than 10 hours, But you could extend that time to be nine hours, meaning instead of uh, which will give you your 7.5, 4 30 would be 8.5. So that means if you go till five Then that is going to say nine hours, that will include your launch and all that other stuff. So you're when you're writing down your time, you should actually put in all that time, including breaks and everything else to be yours, your complete time of class. Another thing that you're going to see that a lot of people try to get over or used to down, they don't do this anymore because all the instructors, no, but they try to squeeze in A full 10 hour class in one day And then they're done. All right, let's get all these 10 hours in and then we don't have to worry about the social thing for the rest of the week. You can't do that one either 7.5 hours is the max. So that means you need at least two calendar days for 2, 10 In at least four calendar days for the 30 hour, No way around that one. You gotta have it. So that's one of the keys there. If anybody misses you do have to, they do have a time frame that they could come back and you know, make up the time. I believe it's six months. I've got it here, I should look, it is six months looking and according is OSHA training class must be completed within six months at the start date. So that's again, I one of the things that you can do if you did not know is you can actually do your training and you could do it in smaller increments intervals. So therefore You can actually have a minimum of 30 minutes And that's it. So let's say you want to just do your 10 hours, 30 minutes at a time because every morning you could do, let's say you could do a tailgate meeting. That's one of truly everyone should know this. But in case you don't, a tailgate meeting is when you are a tailgate of the truck and everyone goes over what you're about to do. So that's the tailgate meeting. So you could do if you wanted to 20 tailgate meetings half hour each and you'll still be good As long as you get this done within six months of when you started day one. So that's the key for the classroom style. Generally, OSHA will tell you how they prefer styles, but they don't want you to do too much video. They like you to mix up the media. So you could do a presentation style, you could do question and answer, You could do um having people look at situations and you can do case studies. That's okay. But OSHA doesn't want you sit in front of the video, Youtube or something and then go ahead and let everybody just watched the videos and you collect the cash, Not a fan of that one. OSHA does not like that. So they say 25 is your max of video for classroom time. So you're gonna have to figure out what that means to you as far as 25% a quarter of the time. So I would imagine it's 2.5 hours, right? Would be what we're looking at. That's a long time for videos. But I guess if you're looking over a full 10 hour mhm. Because you're only going to be doing like what, 10, 15 minutes maximum time? Yeah. So therefore can't do a video heavy. How's that? Once you have your students and you're done? Mhm. You're actually going to need to submit these things and uh send it off to um your O. T. I. Very quickly. So ocean wants to make sure that within 30 days of a class that you're going to go ahead and submit everything that was done so that that everyone gets credited. I forgot one thing. Let me only go back with with one thought that I kind of forgot to mention before. Um when you do your actual OSHA classes and um you're supposed to go ahead and do this training. OSHA really wants you to do it by itself. Like for instance, I do a 10 hour class but it's a component of a larger class. You're allowed to do this. However, OSHA says you could do this in a certain way. So this one I do want to mention on the stand alone one. All right. So the stand alone and here's the wording OSHA outreach training program courses, considered stand alone courses and it must be conducted as part and must not, excuse me, be conducted as part of or in conjunction or combination with other OSHA outreach training programs, meaning you can't do a 10 hour construction and a 10 hour general industry in a mixed audience and combine your introduction to OSHA between the two. They don't allow for that. You have to have them separate. However, though she says this does not prevent organizations from developing wraparound coursework that is not part of the ocean outreach program, meaning Like what I do, I have the 10 hour, but it's only a component of a larger course. So I'm allowed to do that as long as I don't offer to OSHA outreach things at the same course. So what I would end up having to do at that point would be the introduction to OSHA twice. So who wants to do that? Right. So therefore it's going to be two different courses. When you're doing that type of setup, you're going to skip down just a little bit more. OSHA does have your training topics and really make sure that you you do the time right for your mandatory topics and your elective topics and optional topics. That's one of those things that OSHA will look for the time because it is specific time allotted. So just make sure you look for that. Some topics are ineligible to be called OSHA training. So here is one of those, Well, I'll give you all look according to OSHA. So zip topics, not occupational health and safety topics that deal with hazards and prevention. They cannot be used. And this will probably be for your there's elective and then they're optional training. So your electives are set topics, but your optional, you can actually have other things. So cpr first Aid is not allowed for the OSHA optional training part and you must make sure training conducted to comply with OSHA standards cannot be counted towards the OSHA outreach training. Again, this is what I first mentioned in the beginning was you definitely want to make sure that you do not say in any way that this is going to get your client or potential client OSHA compliant because that's going to be a different thing. However, there are some Of states that will require that you take a 10 hour, usually its construction in order for you to to be able to work in their state. That's a requirement by the state, not by OSHA. So therefore uh you just want to make sure that you you know the difference there as a trainer. OSHA gives you plenty of resources so you really need to go on the OSHA website and look on the Susan Harwood Grant material. You can look for uh the OSHA outreach trainer material. They give you power points, they give you handouts. The introduction to OSHA is mandatory handouts that you need to do and activities. So you have to go on the OSHA website for that one as well. one of the big things that we really got to do nowadays with the pandemic is you actually need to truly understand how to write a letter to Osho and it's going to be your duty you see and you're going to write a letter to them asking them to allow you to teach alternatively, meaning I can't teach in the classroom for a specific reason in this case is pandemic related, but I can actually do this online. Here is what I need. So you have to write a letter asking permission every time you do an online training uh to your O. T. I. And you're gonna tell my narrative of why you need it. You're going to tell them, uh, what is going to be covered during that time period. You're going to tell them, you know, your name, give them your credentials and everything else. A copy of your trainer card is going to go in that letter and just everything class dates, who the client is. Um, if it's open enrollment, put that in there as well. So that's some of the things that you're going to be looking to do and you have to give yourself some time to get this approved. So I would say if you're going to do a class and it's going to be online and you know about it two months ahead awesome. However, if you only know about it two weeks ahead, you need to cement that paperwork, a SAP to Euro T. I and see if you can get them to uh to approve it. So I got a couple of little small nuances. I'm going to go over to wrap this thing up because they didn't wanna, again, 38 pages. I'm not going to give you guys everything, but I'm just going to give you things that will really make a difference for you. So when you are advertising there are strict restrictions on what you could say. You can't make anything deceiving in the way that people may think your classes being presented from OSHA, that one is not one that you could use. I'll get you in trouble. So make sure you do not use that one. If you do have an interpreter, this is a big one too. Some people actually need interpreters for any other training. So I would say your interpreter has to know safety and health. That's that's really what it is. So, the the interpreter qualification is that they have a background in safety and health. If you have an interpreter, then the class must be held for twice the amount of the time To allow for adequate interpretation. So that one is a tricky one. So that is pretty much the crux of everything. There's a lot of little nuances there. The minimum class size is three. You got to make sure you know that one there's jurisdictions issue. Make sure you definitely teach within oceans during this is the jurisdiction don't have more than 40 students. And who really wants 40 students anyway. Right. Let's just outrageous. So, those are some of the things that I should has for you. Mhm. Sign in sheets, all that stuff. So go through that that form and it's going to really help you guys out. All right. So that is it for me for this week. You guys could do this thing. Right? I don't get I go ahead and sign off. I got you. So if you have not go ahead and like and subscribe to this podcast, share it with some people and please, if you have a chance, I would love love love if you were able to rate and review uh this one as well. Mhm Thank you. Go cam. This episode is powered by safety FM. 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