This is a First Look at a column to appear in the May issue
of Water Well Journal
Assure employees with limited English ability truly understand safety when on the job.
By Alexandra Walsh
Increasing diversity in today’s workplace is putting more and more focus on issues regarding language and literacy. As such, a concern for supervisors and managers should be determining whether their safety training for non-English-speaking employees is adequate.
In other words, do the workers really understand?
Do you or your supervisors know how to communicate safety training to employees whose first language may not be English? Do you understand the legal requirements for teaching these important policies?
Hispanic construction workers with limited English skills suffer more accidents on the job. Workers who don’t speak English, or have limited ability, can’t communicate as effectively with their English-speaking supervisors, co-workers, or customers. They may also find it difficult to comprehend the requirements of their jobs, if conveyed in English.
Some employees may also not read English understandably, and some may only be able to read very little in English or even their first language.
Unless these language and literacy issues are addressed by management, it will be difficult or perhaps impossible for some employees to work effectively and safely.
This means training comprehension takes on even greater significance when the topic is safety. Inadequate safety training of non-English-speaking employees can result in lower productivity, more errors, and injury or death.
The Occupational Safety and Health Administration has made immigrant workplace safety a priority within the agency. While overall workplace fatalities have dropped 20% in the last decade, workplace fatalities among Hispanic workers, especially those working in the construction industry, have risen almost 35% in the same period.
It has been nine years since OSHA released a memorandum requiring all employers to offer safety training in a language all employees understand. However, it is worth revisiting the OSHA rules, especially since they require OSHA compliance officers to monitor the effectiveness of on-site training for non-English speakers.
Since the purpose of required OSHA training is to create a safer work environment built in part on the correct actions of workers, employers are responsible for making sure their workers are getting information they truly understand. It’s not enough to make people sit through a class and just check their names off.
The OSHA memo (see box above) specifies an employer must instruct their employees using both a language and vocabulary the employees can understand. For example, if an employee doesn’t speak or comprehend English, instruction must be provided in a language the employee can understand.
Similarly, if the employee’s English vocabulary is limited, the training must account for that limitation. Employers are expected to realize that if they need to communicate work instructions or other workplace information to employees at a certain vocabulary level or in a language other than English—they will also need to provide safety and health training to employees in the same manner.
When it comes to training, there are two basic paths laid out for employers: Train your workers in English so you can provide OSHA training in English, or provide OSHA training in your workers’ primary languages.
Many OSHA training requirements dictate the trainees must have an opportunity for interactive questions and answers with the training instructor. So there are no shortcuts available. You can’t simply have another worker pass the information along second-hand.
There are a few critical training issues the memo calls out, while repeating employers have an added responsibility on these particular issues not only to train but verify their workers fully comprehend the training material, and ongoing comprehension as well.
Some standards require retraining if a worker is no longer able to demonstrate the required level of understanding and ability. These include lockout/tagout procedures and correct use of a respirator and understanding when one is required.
Because of the high risk of injury, illness, or fatal accident involved, employers who are deemed deficient in maintaining the required training standards in these and other areas may be cited for serious violations.
Tips for Training Non-English Speakers
How can managers be more confident non-English speakers are understanding their safety training? Here are some things to keep in mind when it comes to training your workers with limited English ability.
Don’t assume employees can read.
Although one way to assist non-English speakers is to display signs and posters in Spanish, for example, this is not always helpful. Employees with limited English skills may also be unable to read in their native language. So written safety materials translated into another language would not be all that useful.
Conduct assessments on employee language and literacy ability in a lawful manner. If necessary, make sure you provide both written and verbal safety instruction to all employees.
Give them all of the training.
Don’t shortcut training or provide non-English-speaking workers with bare minimum instruction on what needs to be done. Most jobs require some level of decision-making. If workers don’t have all of the information, their ability to make correct decisions decreases; their likelihood of accidents increases.
Be aware of cultural differences.
The meaning of certain colors and symbols may differ by culture. It might be considered rude to ask questions or question authority. Modes of dress may interfere with safe work practices. Recognize these differences and take them into account.
Think beyond Spanish.
Many employers accommodate two languages, English and Spanish, but many workers speak other languages. If you have employees whose first language is neither English nor Spanish, you may need to provide them with the necessary training by using translation services (both written and verbal).
Make sure the training is effective.
- Speak slowly, explain, and repeat important points several times.
- Choose the simplest words and avoid technical expressions. If you have to use technical terms, explain them as simply as possible.
- When instructing employees with minimal or limited English skills, consider using a translator.
- Use visual aids, pictures, and props to supplement your words.
- Encourage participation. Be patient and help employees express their thoughts and questions about the topic.
- Have employees demonstrate skills taught during the training session so you can verify they understand what’s been taught.
- Be sure to get feedback to confirm employees are comprehending, and allow extra time for questions.
- Pass out handouts in the language or languages the trainees can understand.
- Follow up later on the job to make sure there were no misunderstandings, and employees are correctly applying what they’ve learned.
Effective safety training for non-English-speaking workers is not just important to your company and employees, it’s an OSHA requirement. Know what your employees need to know and find the best training solutions available. Keep all workers, regardless what language they speak, safe.