Jerry Peters, RSM Corporate OSHA Compliance Mgr. Rumpke Consolidated

Companies

Who Trains Temporary Who Trains Temporary Workers?Workers?

(and more……)(and more……)

Do hard hats work?Do hard hats work?

•If you don’t wear yours your head could end up

looking like this

ObjectivesObjectives

• Temporary help facts, history and info

• Definitions important to the subject• Recordkeeping (OSHA Part 1904)• Training: who, what, why, when,

where and how• Rumpke training and partnership• Class participation exercise

Temporary Worker HistoryTemporary Worker History

• William Russell Kelly- 1946• “The Kelly Girl” (1956)• Kelly coined the phrase

“temp helper”• Today Kelly Svcs. chooses

clients very carefully (safety record/hazards and nature of business)

1956

Temporary Help, History Temporary Help, History and Infoand Info

• Temp worker’s increased due to revised “independent contractor” tax laws in mid 1980’s

• 0.6% of US workforce in 1982 (80K)*• 11% of US work force in 2009 (14M)*• Federal government employment was

up in April 2010 (66,000 temporary workers for the decennial census)*** Source- www.kiplinger.com

** Source- www.bls.gov

DefinitionsDefinitions

• Host employerHost employer - The client (Rumpke, etc.) of a Worker Leasing Company or a Temporary Service Provider who is using leased or temporary employees.

• Temporary Service ProviderTemporary Service Provider – Staffing provider that provides workers to a client by contract and for a fee on a temporary or unknown period of time.

• Professional Employer Organization (PEO)- Provides workers for a predetermined period of time by contract and for a fee to work for a client.

OSHA RecordkeepingOSHA Recordkeeping

• OSHA 1904.31- From OSHA recordkeeping handbook roadmap (www.osha.gov)

– (2) If I obtain employees from a temporary help service, employee leasing service, or personnel supply service, do I have to record an injury or illness occurring to one of those employees?

YES!YES! You must record these injuries and illnesses if you supervise these employees on a day-to-day basis.

TrainingTrainingWho, what, Who, what,

when, where, when, where, why and how?why and how?

Challenges to TrainingChallenges to Training

• Possible language barriers (Latino, Samoan, etc.)• Dedication (employer and

employee-opinion/morale)– Host employer (The water faucet theory or “Not my ee”– Temp employee “They have other assignments for me”

• Temporary employer safety training is usually very generic

• Hazard assessment performed by temporary employers are generally not sufficient to indicate all hazards at host employer sites

• Management using temps for unknown tasks

TrainingTraining

Excerpt from- OSHA Interpretation letter 9/21/2000- – “Although the host employers would, in most

situations, provide the workplace-specific training that is necessary and appropriate for the employees' job assignments and tasks, the temporary agency employer would still have the responsibility to ensure that the employees had been properly trained. Therefore, if a host employer provides any training, the temporary agency employer would have to have a reasonable basis for assessing that the host employer's training is adequate.”

Training- What & HowTraining- What & How

• Training should be specific to the type, size and source of the hazard and or task

• PPE training must be thorough (when, wear, care, limitations, replacement)

• Some training may require classroom and practical (PIT, AWP, Cranes, etc.)

• What- Based on job hazard assessment (JSA)

• Must be in a manner that is understood!

Understood??Understood??WWE- Rey Mysterio video

TrainingTraining

Excerpt from OSHA CPL 2-2.38 (1998)“Furthermore, the training must be comprehensible. If the employees receive job instructions in a language other than English, then the training and information to be conveyed under the HCS (Haz-Com) will also need to be conducted in a foreign language.”

Training- Who & WhenTraining- Who & When

• All employees (temps included)• Some OSHA regs require prior to

assignment (Ex: PIT, AWP, conf space, etc)

• Some require on 1st day (Ex: EAP, Warning signs and tags, right to know, fire ext, etc.)

• Some require refresher (Ex: Hearing cons, Respirator, BBP, fire ext, etc)

Fire ExtinguishersFire Extinguishers

• OSHA 29 CFR1910.157(g)(1)-– 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 fire fighting.

Why and Where?Why and Where?

• The why is evident!!• Where, this is up to you…

– Host employer’s site (General, Specific and Advanced)

– Temporary Employers Site (General)– Shared (Recommended)

• Temporary employers site (General)• Host Employer’s site (Specific and Advanced)

Example of no training…Example of no training…

The next slides are graphic and could be upsetting. If you are offended by scenes

of injuries please look away now

Simple training (15 minutes)Simple training (15 minutes)

This simple training may have This simple training may have prevented this incident:prevented this incident:

• Never:– Stand on the traffic side of the truck

when using the controls to cycle the packer body

– Walk across into incoming traffic– Be on a roadway without your reflective

PPE– Look into the rear sill of the packer body

or stand where items being compacted can fly out can hit you

Paint spray can burst and paint hits Paint spray can burst and paint hits helper in the face helper in the face

What did we do?What did we do?

• Developed job/task list for temp laborers• Developed general Rumpke safety training

programs• Strict responsibilities in service contract with

temporary labor companies• Required temporary employer to

conduct “Rumpke general safety training”• Temporary labor company

trainers must attend train-the-trainer course at Rumpke

• Must sign off on Rumpke training form and fax to Rumpke before temp laborer reports

Rumpke Temporary Employee Training Certification Form

This form shall be filled out for each temporary employee being assigned to work at Rumpke locations. The temporary employee upon receiving training in each section shall sign and date the appropriate section for the work being assigned to complete at Rumpke (Landfill, Driver Helper, Recycling, etc). The trainer’s signature will certify the trainer completed this section with the employees. This form must be faxed immediately upon completion of training to the appropriate location where the temporary employee is being assigned to work. _ ______________________ _ ______________________ Employee Name (Print) Trainer Name (Print)

DRIVER HELPER Section Trainee Signature Date Trainer Signature Date 1- Introduction 2- OSHA 3- Manual Review

4- General Safety

RECYCLING EMPLOYEE Section Trainee Signature Date Trainer Signature Date 1- Introduction 2- OSHA LANDFILL EMPLOYEE Section Trainee Signature Date Trainer Signature Date 1- Introduction 2- OSHA OFFICE EMPLOYEE Section Trainee Signature Date Trainer Signature Date 1- Introduction 2- OSHA I (trainer) certify I have completed the required Rumpke training course for the temporary employee that will be assigned to Rumpke. I understand this training can be audited at anytime for course content. ___________________________ __________ Trainer Signature Date

Temporary Employment Agency completes generic training per line of business.

Both temp agency trainer and temporary employee sign form.

Copy faxed to Rumpke for filing.

Average Retention RatesAverage Retention Rates

0%

10%

20%

30%

40%

50%

60%

70%

80%

90%Lecture

Reading

Audio-Visual

Observing Demo

Visual

Practice bydoing

Immediate use oflearning

* Source: OSU Psychological Study- 2005

Rates of Forgetting Rates of Forgetting ContentContent

Point In Point In TimeTime

RetainedRetained ForgotteForgottenn

1 day 54% 46%

7 days 35% 65%

14 days 21% 79%

21 days 18% 82%

63 days 17% 83%* Source: OSU Psychological Study- 2005

Work shopWork shop

• Case #1- Garbage Truck

• Case #2- Hospital

• Case #3- Printing company

SummarySummary

• Temporary employees must be treated as host employer employees

• Training must be performed based on hazards

• Training responsibilities may be shared (Temp company-general/Host employer- Specific)

• Service contract should set clear direct responsibilities of both parties

Questions?Questions?

Assistance (day 1 Assistance (day 1 comments)comments)

• Checklist for new, rebuilt, altered, modified equipment (Rumpke form)

• Baler, Shear, C/S training programs (will share)• Free trng programs- siri.uvm.edu• JSA’s (safety manager software)• Selling safety to the money men (OSHA safety

pays)• Toolbox talks (dhoward@esiwaste.com)

• Safetyinfo.com• Safteng.net

Thank you for your Thank you for your time time

and attention!!and attention!!Jerry Peters, RSM

gerald.peters@rumpke.com(740)207-0905