EHS TRAINING PROGRAM
Approved by James Basore
Work Process A. Required Training Process24.9 Source Requirements
Work Process B. On-the-Job Training (OJT)
Work Process C. Implementing New Training Requirements
Work Process D. Training Records
Work Process E. Training Systems
Work Process F. Instructor Qualification
24.10 Reference Documents
NOTE: . . . . . Denotes a new section. . . . . . . . . Denotes the beginning of changed text within a section. . . . . . . . . Denotes the end of changed text within a section.
It is Lawrence Berkeley National Laboratory (LBNL) policy that all employees, affiliates, contractors, and others who perform work at, or for, LBNL receive appropriate training commensurate to their responsibilities as required to perform their work in a safe and environmentally sound manner. The Environment/Health/Safety (EHS) Training Program provides training to help ensure that all such personnel know the hazards associated with their jobs, understand the possible health and safety effects of exposure to those hazards, and know how to perform operations safely and in accordance with all applicable work practices and environmental protection requirements.
The EHS training policy is based on operational needs; state and federal laws and regulations; Department of Energy (DOE) orders; Environment, Safety & Health (ES&H) standards; contract requirements for vendors and construction subcontractors; and LBNL policies and guidelines.
The EHS Training Program is a coordinated institutional training program that helps ensure that LBNL employees, affiliates, contractors, and others who perform work at or for LBNL receive appropriate training necessary to protect their health, and to perform work in a safe and environmentally sound manner. The EHS Training Program uses a systematic and risk-graded approach, based on assigned responsibilities and activities performed. This document defines the EHS Training Program as it applies to required job or activity-level training and explains the roles and responsibilities for the development, delivery, completion, records management, and assignment of training requirements.
This policy applies to all LBNL employees, affiliates, contractors, and others who perform work at or for LBNL, and LBNL-controlled off-site locations and facilities, including UC Berkeley-controlled spaces. Note: From here forward, the term “worker” is used to represent this group.
With the exception of General Employee Radiological Training (GERT) and Construction Subcontractor Safety Orientation Training, the contents of this chapter do not apply to subcontracted work by vendors or construction subcontractors who perform work under the Subcontractor Job Hazards Analysis (sJHA) process or Construction Job Hazards Analysis (CJHA). Prior to their arrival at LBNL, these workers are required to satisfy, through their employer, training requirements to meet state and federal laws and regulations; Department of Energy (DOE) orders; Environment, Safety & Health Standards; contract requirements; and LBNL policies and guidelines. EHS may require validation of completed training, and may also require gap training by their employer at their expense when, for example, EHS has additional requirements (specific to LBNL) that the worker needs to complete, or when there is evidence through work observation or other means that the worker needs additional training. However, only the worker’s employer, not EHS, is responsible for ensuring that their workers have met all training requirements applicable to the type of work they are hired to perform at LBNL. At the discretion of LBNL, EHS may provide gap training in some cases. Any gap training provided by LBNL is only applicable to work being performed at LBNL. For additional training guidance for construction subcontractors, see Work Process E, Required Safety Training, of the ES&H Manual Construction Safety Program.
- Waivers from Required Training:
- Waiving a training requirement is a way to remove the requirement.
- A waiver may be granted by the activity lead or activity lead designee through the work authorization process under the following conditions:
- The worker is not performing work that requires the training.
- The activity lead can waive their worker’s training requirement only if his or her work does not involve hazards that require the training, or it is below the level of hazard that necessitates the training. For example, if a worker is assigned ladder safety training but never performs work on a ladder, the activity lead can waive the requirement, because it is not applicable.
- The worker works solely at another institution (such as the UC Berkeley campus), and his or her work-related training requirements are solely governed by this entity.
- If a worker believes that a training requirement is not applicable, he or she may contact his or her activity lead or supervisor, or EHS Training, for guidance and support.
- Training Credit by Equivalence:
- “Equivalence” is the process by which EHS Training gives a worker course credit for an LBNL course because the worker completed an equivalent course at another institution. For example, certain trainings completed at other Department of Energy (DOE) facilities, related institutions (e.g., UC Berkeley), and off-site training providers can be recognized as equivalent to LBNL trainings.
- A worker requests equivalence credit by sending the official training transcript indicating the completed training course, the institution/vendor that provided the training, the date of completion, and contact information to EHS Training at [email protected].
- EHS Training then reviews the transcript and works with the responsible subject matter expert (SME) to evaluate whether the training is equivalent, or whether site-specific gap training is needed to ensure the individual understands applicable LBNL safe-work practices and policies.
- Equivalence is also granted for courses that the DOE National Training Center has qualified as reciprocal.
- EHS Training reports through EHS Division Senior Management.
- EHS Training is a collaborative endeavor with LBNL division management, subject matter experts, division-level training functions, division safety coordinators (DSCs), line management, safety advisory groups and committees, EHS instructors, and the Information Technology (IT) Division.
- Line management provides on-the-job training (OJT) as well as training that is specific to the work conducted in its actual environment, and ensures that training requirements are met.
- EHS Training has partnered with EHS IT to maintain the Berkeley Lab Training system(s).
- EHS Training supports division-level training needs by providing:
- Guidance and support for the design, development, implementation, and evaluation of division trainings
- Access to EHS training systems used to manage, deliver, and track training requirements
- Access and support for managing training records and reports
Division managers with DSC support
- Review its operations and facilities to identify any ES&H training needs that are not already specified as institutional training requirements for anyone performing work within the division’s area of control.
- Inform EHS Training when implementing local training requirements delivered through the Berkeley Lab Training system(s) and where institutional record keeping is required.
Line managers (supervisors, project leads, activity leads)
- Identify qualification and training requirements for workers working on activities under their responsibility.
- Provide on-the-job training, as needed, to help ensure workers are able to perform their work safely and in accordance with their assigned work responsibilities.
- Ensure that workers have the necessary resources and time to complete their required training.
- Ensure that workers satisfactorily complete all required EHS training before performing the work or activity. If training has not been completed, ensure that workers are not performing any work that requires the training. In some cases a worker may perform work while they are in the process of completing training, but there are conditions for this allowance. Refer to Work Process A.6, Completing Training Requirements.
Workers (employees, affiliates, contractors, and others who perform work at or for LBNL)
- Satisfactorily complete all required training, including training mandated by LBNL and any training associated with a work assignment on initial hire and, as applicable, when assigned to a new position, task, or activity with new hazards.
- If required training has not been completed, worker cannot perform any portion of the work or activity requiring that training. However, a worker may be able to perform work while their training is in progress, but there are conditions for this allowance. Refer to Work Process A.6, Completing Training Requirements.
- Discuss with supervisor any additional training needed to maintain and improve ability to perform work safely and effectively.
- Notify EHS Training if course completion record is inaccurate.
- Provides a training curriculum that addresses pertinent regulatory requirements, LBNL policy, and best practices; and that provides the necessary knowledge, skill, and awareness to operate in a safe and environmentally protective manner.
- Works with EHS programs to analyze, design, develop, implement, and evaluate curriculum and trainings in alignment with DOE’s Alternative Systematic Approach to Training (DOE-HDBK-1074-95).
- Works collaboratively with division-level and program-level training functions to design, develop, and evaluate instructional programs and courses.
- Works with SMEs to interpret external training requirements and provide recommendations for their implementation at LBNL.
- Reviews EHS training requirements and approves any significant changes as needed.
- Manages the Berkeley Lab Training systems and Berkeley Lab Training website in partnership with EHS IT.
- Manages institutional training records and ensures that training-related records and reports are accessible for use by workers and Laboratory management as appropriate.
- Ensures that required courses are made available to employees, affiliates, contractors, visitors, and all those who perform work at, or for, LBNL.
- Assigns internal course codes for external courses as needed.
- Notifies supervisors and affected workers of new or changed training requirements if these changes require action on their part.
- Establishes and maintains EHS Training policies, programs, and procedures.
- Works with line management to support and qualify EHS instructors.
Safety Advisory Committee
- Provides input on the EHS Training Program and policies.
- Provides input on significant changes to EHS training requirements as well as newly proposed courses that have a significant impact on LBNL, and ensures these efforts meet the needs of the Laboratory.
- Work with EHS Training to design, develop, and deliver training in accordance with DOE’s Alternative Systematic Approach to Training (DOE-HDBK-1074-95).
- Work with EHS Training to schedule sessions to meet customer’s needs.
- Work with EHS Training to review training and make improvements as agreed.
- Work with EHS Training to ensure content is accurate and up-to-date.
- Work with EHS Training to develop effective teaching skills.
The process of validating performance and/or compliance with the requirements of established standards. Typically, this means obtaining written verification of worker’s compliance with specific requirements.
Training that is designed to address a lack of skill, or lack of knowledge about a particular policy, work process, or procedures applicable to performing work at LBNL. For example, if a worker completed fall protection or electrical safety training at another institution, EHS may require the worker to complete a gap training in order to ensure the worker understands LBNL-specific work requirements and expectations. This may be either a formal training or an informal training based on determined need.
A process of issuing LBNL training credit for having completed an equivalent training at another institution.
Institutional training requirements (ITRs)
Training requirements that apply to a particular category of workers throughout the Laboratory and that consist of legal, contractual, and LBNL-specific requirements. Legal requirements are based on a law, regulation, rule, or statute (federal, state, or local). Contractual requirements are those requirements that are stated in the LBNL contract, and include DOE orders and directives as well as LBNL policies. Laboratory-specific requirements are requirements that LBNL imposes on itself based on operational need.
Local training requirements (LTRs)
Training requirements that apply to a localized activity, work area, division, or facility. These can be generated within a division and are directed to workers performing work in that division or facility.
On-the-job training (OJT)
A training process used to ensure that workers are qualified to perform their specific work activities and tasks safely and effectively. It is an iterative performance-based process that involves experienced staff (activity lead, activity lead designee, or supervisor) training a less experienced worker until he or she can demonstrate, to the trainer’s satisfaction, an appropriate level of understanding and mastery of the tasks. Refer to Work Process B, On-the-Job Training.
The combination of an individual's physical abilities as well as his/her technical, academic, and practical knowledge and skills as developed through training, education, and on-the-job performance. Required reading may also be part of an individual’s qualification. In some cases, qualifications may be formally evaluated and documented.
A process of removing a training requirement because the worker does not perform the work that requires the training. In this way the training requirement is not applicable. See Section 24.4.1, Waivers from Required Trainings.
Work Process A. Required Training Process
Work Process B. On-the-Job Training (OJT)
Work Process C. Implementing New Training Requirements
Work Process D. Training Records
Work Process E. Training Systems
Work Process F. Instructor Qualification
This section describes the process for identifying, assigning, completing, and documenting training requirements.
- Basis for Requirements. Workers performing work at, or for, LBNL are expected to be capable of carrying out their work safely, securely, and effectively. In many cases, specific skills, knowledge, and abilities are required in order to be assigned a particular job, qualified to perform a certain activity, or to be allowed to work in a particular facility. Completion of required EHS training courses provides greater assurance that workers will be aware of the hazards associated with their job or activity, understand the possible health and safety effects of exposure to those hazards, and know how to perform operations safely and in accordance with all applicable work practices and environmental protection requirements.
- Origin of EHS Training Requirements. EHS Training requirements originate in several ways, either within or outside the organizational group to which they apply. Sources include DOE orders and regulations, OSHA regulations, EPA regulations, Department of Transportation regulations, the California Code of Regulations, LBNL’s environmental permits, LBNL’s Operating and Assurance Program, and LBNL policies and best practices. Requirements derived from non-LBNL sources are restated in terms appropriate to LBNL by the applicable EHS program or policy owner(s) with support from EHS Training.
- Types of Requirements. There are two types of training requirements: institutional training requirements and local training requirements:
- Institutional training requirements (ITRs) apply to workers throughout LBNL and consist of legal, contractual, and Laboratory-specific requirements.
- Legal requirements are based on a law, regulation, rule, or statute (federal, state, or local).
- Contractual requirements are those requirements that are stated in the LBNL contract, and include DOE orders and directives as well as LBNL policies.
- Laboratory-specific requirements are requirements that LBNL identifies based on operational need.
- Local training requirements (LTRs) have a narrower scope than ITRs. They apply to workers who perform work within a division or facility. For example, a division may require orientation training for all those who perform work in the division, or a facility manager may require training in order to gain access or perform work within a facility. LTRs are often driven by division-level operational needs, which may or may not be driven by legal or contractual obligations.
- Identifying Training Requirements. Training requirements are identified by line management, division management, and LBNL programs:
- Line managers identify which training requirements apply to their workers by using the Integrated Safety Management (ISM) and Work Planning and Control (WPC) process. This involves defining work, analyzing hazards, and identifying required controls, including EHS-required training. In addition, line management provides on-the-job training, which is described in detail in Work Process B, On-the-Job Training, below. Line management also works with staff to identify any staff development training, formal or informal, to build or further develop needed role or job-related competencies.
- Division management identifies which training requirements apply to workers performing work in the division. This is done by examining all institutional training requirements, evaluating existing divisional requirements, and considering whether new local training requirements are needed.
- LBNL programs identify which training requirements apply to workers within its area of responsibility. This is done by evaluating applicable legal, contractual, policy, and programmatic needs.
- Assigning Training Requirements. Once training requirements have been identified, they are assigned via the Work Planning and Control process or via the Berkeley Lab Training system.
- The Work Planning and Control process assigns activity-related EHS trainings, and in some cases, division-specific training. For example, a work activity that involves the use of chemicals may require EHS 0348 Chemical Hygiene and Safety.
- The Berkeley Lab Training (BLT) system assigns institutional training requirements that are not associated with a particular hazard or work activity. Examples include EHS 0470 General Employee Radiological Training and non-EHS training requirements, such as RII 0004 UC Ethical Values and Conduct, SEC 0201 Cyber Security, and SEC 0500 Hosting Foreign Nationals.
- In most cases, workers receive training from both the Work Planning and Control system and the Berkeley Lab Training system. Workers can review their training status for all training requirements by accessing their LBNL Training Profile at training.lbl.gov.
- Once a training requirement is assigned either by Work Planning and Control or the Berkeley Lab Training system, EHS Training informs workers and their supervisor via email notifications. Go here for details about these notifications.
- Completing Training Requirements
- Workers must complete assigned EHS training that is legally mandated or that is required as part of a work assignment on initial hire (appointment), whenever he/she is assigned to a position or activity with new hazards or conditions that require training, and whenever he/she is assigned refresher trainings.
- Workers who have not completed assigned EHS training that is required as part of their work assignment cannot perform any portion of the work that requires that training.
- For example a worker cannot operate a powered industrial truck until all associated training requirements are completed. The same is true for operating a crane, performing radiological work, using a respirator, entering a confined space, or work that involves the use of fall protection.
- However, there are some cases when a worker may be able to perform work while his/her training is in progress. This allowance is designed for situations when, for example, the required training class is not available because of scheduling. When allowable, the worker must work under direct supervision of a trained and knowledgeable worker and with approval of his/her supervisor or activity lead.
- Since there are many factors that inform whether a worker can perform work while training is in progress, EHS Training can provide guidance.
- To receive credit for training, workers must satisfactorily complete the training and pass any examinations or practical observations.
- Documenting Training Completions
- EHS Training documents worker’s training completions in accordance with DOE Administrative Records Schedule 29.2. See Work Process D, Training Records, below.
- Workers can view their training completions and training status by accessing their LBNL Training Profile at training.lbl.gov. The LBNL Training Profile is the official training record. It provides workers with a comprehensive view of their training requirements as well as completion dates and completion status of all trainings whether required or not. It also provides direct access to trainings. A worker can also view the training status of activity training requirements through the Work Planning and Control Activity Manager system. Activity Manager does not report on the completion status of institutional training requirements since these are not specific to work activities.
- The distinction between Berkeley Lab Training and Activity Manager is that the Berkeley Lab Training System’s Training Profile provides a comprehensive report of all training requirements (safety and non-safety) whereas Activity Manager provides the status of activity-related safety trainings.
- In addition to these sources, the Berkeley Lab Reporting Portal can be used to build a comprehensive training summary report that shows a worker’s entire training history. For example, the LBNL Training profile will show the last time you completed EHS 0470, General Employee Radiological Training (GERT), whereas BRS will show each date you completed GERT.
- EHS Training can provide training records upon request.
- Required Training for Personnel at Off-Site Locations
- All LBNL workers working on LBNL projects at off-site locations, including UC Berkeley-controlled spaces, are required to adhere to training requirements as stipulated by the host institution or Partnership Agreement on ES&H. In the absence of a Partnership Agreement on ES&H or host institution requirements, LBNL requirements must be completed.
- In some cases, facility or procedure-based training, specific to the location, will fulfill a training requirement. Contact EHS Training for assistance.
Diagram of Required Training Process
This section describes on-the-job training (OJT) within the context of worker qualification.
- Worker Qualification. Line management has a responsibility to ensure that workers are qualified to perform their work activities and tasks safely and effectively. Qualification to perform work includes both an operational and a safety component. The safety requirement is that workers must be knowledgeable and familiar with the hazards and controls associated with each of their assigned tasks and demonstrate an ability to perform their work activities safely. While formal EHS Training courses can provide background information on the majority of hazards and controls, they aren’t necessarily designed to provide detailed information specific to an individual’s work and work environment. This is the responsibility of line management and is most effective when integrated into the scientific, technical, quality, efficiency, and/or other operational aspects of qualification.
- On-the-Job Training (OJT). A common method to ensure that workers are qualified to perform their work activities and tasks safely and effectively is to perform OJT, which is an iterative process whereby the trainer who has the skill, knowledge, and experience (for example, the activity lead, activity lead designee, or supervisor) works with the trainee until he or she demonstrates, to the trainer’s satisfaction, an appropriate level of mastery of the tasks.
- Graded Approach. The degree of formality and the comprehensiveness of training should be graded to the overall risk. It is expected that the higher the risk, the more effort and care will be expended in ensuring that workers are appropriately qualified (competent). This can be broken down as follows:
- Higher Risk: This includes activities or tasks that involve Risk Level 3 hazards as defined by Work Planning and Control. Two examples include laser and radiological work. Training/qualification and OJT documentation requirements are specified in the formal work authorizations as governed by policies, regulations, codes, and standards.
- Medium Risk: This includes activities or tasks that involve Risk Level 2 hazards as defined by Work Planning and Control. Examples can include work with complex instrumentation or processes. Training/qualification and OJT documentation requirements are driven by a blend of line management accountability and hazard assessment, where the level of qualification documentation, including OJT documentation, is determined by division policies and/or division practices.
- Lower Risk: This includes activities or tasks that involve Risk Level 1 hazards as defined by Work Planning and Control. The method of qualification may be informal, and OJT documentation is at the discretion of line management.
- OJT Method. A common OJT instructional method is demonstration-performance, which can be broken down as follows:
- Explain: The trainer first explains to the worker how to perform the task or activity safely and effectively. The critical steps are identified and differentiated from the non-critical steps. Hazards, risks, and ways to mitigate them are stressed and reinforced throughout the training.
- Demonstrate: The trainer then demonstrates the task exactly the way the worker is expected to perform it. The demonstration can be repeated until the trainee has a clear picture of the action and understands how it is performed and why it is performed that way.
- Perform: The worker then practices the activities and tasks under the guidance of the trainer. As the worker performs each step of the task, the trainer makes comments and corrections as required. When the worker is ready, he or she then “teaches” the operation back to the trainer. OJT is completed when the worker demonstrates, to the trainer’s satisfaction, that he or she has the ability to safely perform the activities and tasks.
- OJT Resources. EHS Training has developed the following OJT resources. EHS Training is also available to help divisions develop an OJT program.
This section describes the process for onboarding new EHS training requirements.
- The EHS Training Program aligns to the guidelines set forth in DOE-HDBK-1074-95 Alternative Systematic Approaches to Training. This forms the foundation for how EHS Training applies a risk-graded but systematic approach to the design, development, implementation, and evaluation of training.
- Any division or program can request a new institutional training requirement through the EHS Course Proposal process. EHS Training must approve all new courses and significant changes and updates to existing courses.
- In some situations (for example, where new training requirements and courses affect large or specific populations at the Laboratory), the EHS Training Program Manager may request additional approval(s). Approval may be from the EHS Division office or senior Laboratory management with advice from the Safety Advisory Committee (SAC) and/or other applicable subcommittees.
- To ensure training resources are allocated appropriately, and to focus attention on the more critical courses, EHS Training follows a risk-graded approach that takes into account (a) the complexity of the job, (b) the consequence of error based on risk/hazards potential, (c) needs framed by regulatory, contractual, and programmatic drivers, and (d) business, legal, or reputational risks that may result from not providing the training.
- The following diagram outlines this process:
Diagram Outlining Process for Implementing New Training Requirements
This section describes training-related record-keeping requirements.
- Training Records:
- The Berkeley Lab Training system and the Human Resources Information System (HRIS) are the official training systems of the Laboratory. These systems generate training data, training reports, training profiles, and course completion records, all of which are made available to workers, supervisors, training administrators, division safety coordinators, UC, and DOE management as needed.
- Individual workers and supervisors can access current training records via the LBNL Training Profile and Berkeley Lab Reporting Portal.
- Records and reports can be requested from the EHS Training Office.
- Training Materials:
- EHS Training maintains copies of training materials in electronic format and has a process for managing training revisions in support of DOE records archiving requirements.
- Training materials include course development materials and content, test data or completions, and if applicable, a course syllabus.
- Record Retention:
- Course records are managed in accordance with DOE Administrative Records Schedule 29.2, and are performed in partnership with Berkeley Lab’s Archives and Records Office.
- EHS training records are managed locally until they are archived off site. In either case, they are available upon request through the EHS Training Office.
This section describes the training systems managed by the EHS Division.
- EHS Training manages the following training systems in partnership with IT.
- Berkeley Lab Training Database
- Course Builder
- Berkeley Lab Training website
- EHS training systems are integrated with LBNL’s Work Planning and Control Activity Manager system, Human Resource Information System (HRIS), and other institutional and division-managed systems that require training data.
- EHS Training and EHS IT are responsible for maintaining the EHS-owned Berkeley Lab Training systems in accordance with business needs.
- EHS Training provides role-based access to EHS-owned Berkeley Lab Training systems based on expressed business needs.
This section describes the process for qualifying EHS Instructors.
- EHS Division line management is responsible for determining the qualifications and the most appropriate candidate for teaching an EHS course. Qualification is based on an individual’s (a) technical competency (knowledge of the subject matter, experience in the work place, and knowledge of the objectives being met in the course) and (b) instructional competency.
- EHS Training works with division line management to help ensure that instructors have the instructional competency necessary to deliver effective training courses.
- EHS Training provides one-on-one support as well as formal Train-the-Trainer courses to support instructor development.
- EHS Training documents instructor qualifications.
- 10 CFR 851.25, Worker Safety and Health Program, Training and Information
- 29 CFR 1910, Occupational Safety and Health Standards
- 29 CFR 1926, Safety and Health Regulations for Construction
- 10 CFR 835.103, Occupational Radiation Protection, Education, Training and Skills