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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5 8.3 9.2.2 10.1 10.2

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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3.8 4.1 4.2.1

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