Training via the web can aid environmental compliance
By Diane Kramer, Ph.D., CEO, MMA/Impletec Group
The responsible people in your organization have memorized emergency procedures in your SPCC, FRP plan, or emergency operations plan, and are ready to act exactly as required . . . or are they? Here are some considerations for maintaining an effective emergency response program.
About the Author
New clients have shared the following stories:
o Staff followed
all emergency procedures during a spill, except one - they neglected to
immediately inform EPA. Result: a very stiff fine.
o At a recent business disaster recovery meeting, half the companies reported they could not find their plans.
o We were told about three government administrators who had been fired because of lack of responsiveness in an emergency.
o We were told about plans that have emergency procedures buried deep within and, as a result, were not easily accessible.
The implications of not having learned the details of a plan to the point of memorized and practiced 'automatic behavior sequences' in an emergency are enormous. Not only might a company pay stiff fines, but damage to the environment, to the organization's reputation, and to individual careers can result. Consider some of the human factors that limit our responses in emergencies and some possible solutions.
Let us start with learning. Once individuals have gone through a training program, they should have mastered the learning materials. But how does a supervisor or a company measure training effectiveness?
There are four ways to measure if training is successful.
Level 1) Reaction. Did they like it and leave with a positive impression?
Level 2) Learning. Did they retain information and are able to demonstrate it?
Level 3) Behavior. Are they doing things differently and able to apply it in the real world?
Level 4) Results. Are they integrating what they have learned to improve the organization?
Most training programs stop far short of levels 3 and 4 - the ability to act quickly and effectively under pressure. Taking effective action under pressure requires repeated training under simulated conditions until mastery is achieved, like the firemen who practice water rescues across from my house on a weekly basis.
Regarding memory, the fact is that the average amount of material retained from reading a plan or from taking a training course is 21 percent in six months - and declines from there. These statistics do not predict a high likelihood of effective response in emergency situations. (To test this, we asked a number of clients to tell us what steps they needed to take in emergencies. If this had been a graded test at school, most would have failed.)
And, there is the human response to stress when we encounter a stressor (anything identified as a threat). Do we act effectively and clearly? In fact, under stress most people go into "emergency operation." Mentally, they shut down and cannot see choices. Panic and poor judgment become the norm. Anxiety, frustration, fear, and dread replace logic.
Given the human factors, it is highly unlikely that people will react appropriately in an emergency without careful and repeated training to behavioral mastery and integration -i.e., levels 3 and 4.
Solutions used by companies include extensive and repeated training for employees to the level of mastery; simulating real emergencies; and sending personnel repeatedly to training programs until they reach a high level of mastery.
But what if they forget? What about new hires or change in roles? What if the training you need is not available when you need it?
A new alternative
There is another emerging solution: e-learning, or online learning. Companies are suddenly demanding e-learning solutions as they come to realize its effectiveness in terms of saving time and money as compared to stand-up training. It has been reported that the EPA and OSHA are now allowing e-learning training to take the place of at least half of all stand-up training, except the field drills. Following are some considerations on how e-learning may play a role as a training solution.
We're not all the same. There are differences in the capacities for learning among personnel. Carefully crafted e-learning programs present mission-critical training materials and problem-solving scenarios for learners to master at their own pace, allowing as many repetitions as necessary to reach mastery. E-learning programs can simulate spills, disasters, earthquakes, terrorism attacks, and then guide learners through problem-solving choices and role plays until mastery is achieved.
We forget easily. Maybe a few people don't need to review and practice, but most of us need follow-up training and drills. E-learning drills and online problem-solving scenarios can be used as follow-up training, appearing on employee screens at odd times to test for the internalization of 'automatic behavior sequences' and for knowledge. Imagine that suddenly a screen lights up with "Emergency! Emergency! Emergency!, and the trainee sees a picture of a spill … a timer starts to run … the viewer is given a list of choices of what to do and has to arrange the right choices in the right order within a certain time limit, almost like a computer game. The score appears on the screen as compared to past performance. Does the score indicate a need to go back and review? With e-learning, material is available at an employee's fingertips.
People respond poorly under stress. It can make a difference if employees know their own stress patterns and are prepared. E-learning programs can contain modules for teaching personnel about their unique reaction patterns during stress and times of emergency and lead them through practice stress-reduction exercises as well as the development of a personal plan of action during emergencies.
People don't like to look bad. We have heard the objection that e-learning is good for practice, but classroom training sets the context for people to make mistakes and learn from those errors. Some say the best way for people to learn is by trial and error in front of others. Actually, while trial and error is the most powerful learning mode, most people attempt to hide their errors in public, to defend their self-worth. They learn less that way, rather than more. A powerful characteristic of e-learning.is its privacy: people can learn by trial and error without feeling embarrassed or humiliated.
We could be sued. What happens if an organization errs in an emergency and gets sued? Might the legal exposure be lessened by proving mastery of the subject matter by employees. Would that make a difference in court? Again, e-learning programs provide tracking of student learning, audit trails, and electronic signatures, features which are becoming important in compliance and regulatory cases where there are liability issues. Certification and re-certification programs can be easily implemented via e-learning as well. In case of problems resulting from inappropriate responsiveness during an emergency, management can demonstrate that they enforced a highly rigorous and responsible training program, thereby protecting the organization. In one case reported to us, the client was sued for liability and was able to document his preparedness through computerized student management reports. The client did not have to pay the penalty.
Updating is expensive. SPCC and FRP plans need to be updated every three years or when the facility changes according to criteria, which means more training time away from the job, or risk not knowing the new procedures during an emergency. Online training materials can be easily updated. Plans themselves can be integrated into an online training and information systems to ease updating.
Training is expensive. Training is, of course expensive, and time away from primary job functions, especially for travel to facilitate training, can be exhaustive. E-learning provides some advantages over initial training.
However, initial costs of e-learning programs are higher than costs for the same amount of stand-up training. Conversely, extensive benchmarking information in the fields of learning and e-learning document that while upfront costs are more for the development of e-learning programs, over two to three years comparable classroom training costs are double e-learning costs.
For those companies who feel that nothing takes the place of hands-on experience, blended solutions are becoming the norm - a combination of stand-up training and e-learning to provide both hands-on experience and the practice and repetition made possible by e-learning.
Compliance and regulatory e-learning programs have already proven themselves useful in the healthcare industry, the pharmaceutical industry, manufacturing, government and defense - places where there are heavy compliance and regulatory issues.