Wednesday, May 26, 2004

OSHA Announces New Grants

Welcome to OSHA's Brave New World

OSHA has announced $5.2 million in safety and health "training" grants.

While $1.2 million are dedicated to OSHA's traditional worker training grants (recipient uses grant money to develop training materials and train workers), $4 million will be awarded to develop training materials.

$4 million for training materials. Does this figure ring a bell? Yes, this is the launch of OSHA's brave new "training" world. You may recall that the Bush administration has attempted to cut the $11.1 million Harwood training grant program -- where workers receive training from actual trainers --to a $4 million training materials program, based on the assumption that it is more effective for workers to train themselves on the computer after work than to receive live, interactive training on work time.

As Assistant Secretary of Labor John Henshaw dissembled said about the cuts in a recent interview:
"I would not use the word "'cutting,'" Henshaw said referring to the proposed $6 million decrease in the training grant program. "We do not feel the training program should be based on one-on-one training. We are developing materials and technology to get information out to more people."
Back in the days when we expected the federal government to follow the letter and the spirit of the law, health and safety training was done on worktime, with live trainers who could actually answer questions and engage the workers in learning instead of sticking them in front of a computer or expecting them to take a CD home with them.

It's the "neutron bomb" theory of training -- worker training without the workers.

OSHA's own publication, Training Requirements in OSHA Standards and Training Guidelines recognizes that effective training is about more than just facts about hazards and how to prevent them
An effective training program allows employees to participate in the training process and to practice their skills or knowledge. This will help to ensure that they are learning the required knowledge or skills and permit correction if necessary. Employees can become involved in the training process by participating in discussions, asking questions, contributing their knowledge and expertise, learning through hands-on experiences, and through role-playing exercises.
Truly effective training is about how to change the conditions in the workplace so that unsafe conditions are recognized and eliminated or controlled. And even if training information is accurate and understood, it isn't too useful for workers who have little knowledge of OSHA and little understanding of their rights.

I've been in the training "business" for a long time, and I haven't met one training expert who has argued that computer -- or even book -- training is superior to interactive training with an instructor who can engage the students, discuss the issues and answer questions.

OSHA has previously funded training materials as a tool to provide effective training. This program is fundamentally different, as described in the Federal Register notice:
While limited on-site training may be proposed for evaluation and validation purposes, the conduct of training programs should not be a significant workplan element in the grant proposal. The training materials are to be developed in portable formats that are suitable for hard-copy publication and distribution and Internet publication and distribution.
As always, OSHA will review the materials for technical accuracy. Otherwise, "success will be based solely on how many copies are distributed or downloaded from the internet.
Grantees developing training materials under the OSHA Training Materials Development grant category will be required to post the training materials on their organization's Web site for two years after receiving OSHA approval of their final products, and provide access to users at no cost....In addition, these grantees will also be required to track and report quarterly to OSHA on the distribution and use of these training materials during the two years the materials are posted on their Web site. Grantees will collect and report on training materials product usage by tracking the number of times the grantee's training materials Web site was visited, and the number of times the training materials were downloaded.
No interest in measuring who is actually using the material (as opposed to just downloading it), how it is being used, or whether it is effecting beneficial change in the workplace. Just the numbers please.

One of the main targets of this program is Hispanic workers. This is a good thing given their high fatality rates, but this is just about the last group of workers who you'd expect to run home after work to fire up their computers and learn their safety lessons.

The only thing I can figure is that the Bush administration must be getting its training advisors in the same joint it gets its "sound science" advisors.

The tragedy here is that while OSHA attempts to cut funding for its worker training program, and then confine what little is left to "materials development," it continues to increase resources devoted to its employer focused voluntary programs.

As I've said before (ad nauseum), unless we have a regime change next Fall, we've probably seen the last of OSHA's worker oriented programs. All that we'll have left is a pat-ourselves-on-the-back, safety-pays, good-old-boys club -- no dirty worker types allowed.

UPDATE: On further reflection, I see a silver lining to these training materials-only grants.

Back in the old days, when you actually had to train real people, you may have found yourself in trouble if, at the end of a quarter, you hadn't trained as many people as you had promised. Nothing to do but develop a good excuse and promise to do better next quarter.

With the new training material grants, you have another option. Say you're approaching the end of the quarter and your new web publication has only received 5 hits, but you had promised 30,000. Just get a bunch of your staff to sit around and open up the document 29,995 times over the next couple of days. Goal met.

Hmmm. Those Republicans are smarter than I thought.