5 Signs Your Health & Safety Training Programme Needs Reviewing

Is your organisation’s training programme genuinely keeping people competent and safe?

For many employers, Health & Safety training is something that is organised when an employee joins the business, when a qualification expires, when new equipment is introduced or following an incident.

However, an effective Health & Safety training programme should be much more than a collection of courses and certificates.

Training needs to be relevant to the work people undertake, appropriate to the risks they face and sufficiently effective to enable them to work safely. It should also evolve as your business, workforce, equipment, processes and risks change.

The Health and Safety Executive (HSE) describes competence as a combination of training, skills, experience and knowledge, together with the ability to apply these to perform a task safely. Importantly, HSE makes clear that training is an important component of competence, but training alone does not necessarily establish competence. (HSE)

So, when was the last time you properly reviewed your organisation’s Health & Safety training programme?

Here are five signs that it may be time for a review.

1. Your Training Matrix Shows Plenty of Certificates – But Not Necessarily Competence

A training matrix can be an extremely useful management tool. It can show who has completed a course, when training was undertaken and when refresher training may be required.

But there is an important distinction between holding a training certificate and demonstrating competence.

A certificate may demonstrate that somebody attended or successfully completed a particular training course. It does not automatically demonstrate that they can consistently apply what they have learned in the workplace.

HSE guidance emphasises that competence involves the combination of skills, knowledge, experience and training, and the ability to apply these safely to the task being undertaken. (HSE)

For example, an employee may have completed training several years ago to operate a particular item of plant. But:

• Have they operated the equipment regularly since?
• Have their practical skills been assessed?
• Have the working environment or site conditions changed?
• Has the equipment been modified or replaced?
• Have operating procedures changed?
• Are they still following the manufacturer’s requirements?
• Do they understand the risks associated with the work?
• Have supervisors observed their performance?

These are competence questions rather than simply training-record questions.

What should employers consider?

A good training review should therefore look beyond the training matrix and consider whether employees can demonstrate the required knowledge, skills and behaviours in the workplace.

Depending upon the risk, this may involve:

• Practical assessments
• Workplace observations
• Knowledge assessments
• Supervisor feedback
• Refresher training
• Toolbox talks
• Competence assessments
• Reassessment following incidents or identified weaknesses

For higher-risk activities, a more robust competence assurance process may be appropriate. HSE specifically recommends that competence assurance is linked to key responsibilities and tasks identified through risk assessment. (HSE)

If your training matrix tells you who has a certificate, but not whether they remain competent, your training system may need reviewing.

2. Your Training Hasn’t Changed – Even Though Your Workplace Has

Businesses rarely remain static.

You may have:

• Purchased new machinery
• Introduced new technology
• Changed production processes
• Altered working methods
• Moved premises
• Taken on new customers
• Introduced new materials or substances
• Changed shift patterns
• Increased production
• Expanded into new areas of work
• Changed supervisory or management structures

Yet sometimes the training programme remains exactly the same.

That can create a significant gap between the risks the organisation actually faces and the training employees receive.

HSE guidance states that ongoing training should be provided when circumstances change, including the identification of additional risks, the use of new or modified equipment and new job responsibilities. Monitoring and review can also help determine whether existing training remains relevant to the job. (HSE)

A simple question to ask

Ask your management team:

“What has changed in our business since we last reviewed our training programme?”

Then ask:

“What impact have those changes had on our training requirements?”

If nobody can provide a clear answer, there may be an opportunity to review your training needs.

Consider your equipment

For example, an organisation may have historically trained operators on a particular type of machine.

If that machine has subsequently been replaced by newer equipment, the operator may require additional instruction or training.

Similarly, introducing new lifting equipment, work equipment, chemicals, production processes or workplace transport arrangements may create new competence requirements.

Training should reflect the actual work environment, rather than simply what appeared on last year’s training schedule.

3. Employees Are Repeating the Same Mistakes

This is one of the clearest warning signs.

If employees repeatedly make the same Health & Safety mistakes despite having received training, it is worth asking whether the underlying issue is really a lack of training.

For example:

• The same manual-handling problems keep occurring.
• Operators repeatedly fail to complete pre-use checks.
• PPE requirements are regularly ignored.
• Workplace transport rules are inconsistently followed.
• Employees continue to use equipment incorrectly.
• Unsafe lifting practices are repeatedly identified.
• Risk assessments are not being followed.
• Supervisors repeatedly identify the same behavioural problems.

The immediate response can sometimes be:

“They need retraining.”

But that may not be the complete answer.

Why are people making the mistake?

There could be several reasons.

Perhaps:

• The original training was too generic.
• Employees did not understand the relevance to their work.
• The procedure is difficult to follow.
• The equipment has changed.
• Supervisors are not reinforcing the expected standard.
• Employees have never had their practical competence assessed.
• Production pressures are encouraging unsafe shortcuts.
• The risk assessment does not reflect actual working practices.
• Employees have forgotten aspects of their training.
• The training did not address the specific problem.

HSE’s approach to competence reinforces the importance of ensuring that training is relevant to the workplace and that competence is maintained rather than assuming that attendance at training is sufficient. (HSE)

Don’t automatically retrain – investigate

Repeated mistakes should trigger a review of the training, competence, supervision, procedures and working environment.

The right solution may be:

Training + practical assessment + improved supervision + revised procedure

rather than simply: Another training course.

4. Your Training Programme Is Driven by Expiry Dates Rather Than Risk

Many organisations understandably use qualification expiry dates to manage refresher training.

This is useful, but expiry dates should not necessarily be the only factor determining when training needs to take place.

A risk-based approach asks:

What does this person need to know and be able to do to perform their role safely?

HSE guidance explains that training requirements vary according to factors including the job or activity, the existing competence of workers, the circumstances of the work and the equipment involved. (HSE)

The appropriate frequency of refresher training will therefore depend upon the circumstances and risk involved.

Consider an employee who performs a safety-critical task every day compared with somebody who performs a complex task only occasionally.

Both may require competence, but their training and reassessment needs may be different.

HSE’s human-factors guidance specifically identifies the importance of refresher training for infrequent, complex or safety-critical tasks, potentially including reassessment. (HSE)

Events that should trigger a training review

Training needs should also be reconsidered following events such as:

• An accident
• A near miss
• An unsafe act
• An equipment failure
• A change in legislation or guidance
• New equipment
• A new process
• A change of role
• A change in working environment
• A competence assessment failure
• An identified skills gap
• A significant change in risk
• Poor audit findings

This means that training should be dynamic, rather than simply a calendar of expiry dates.

5. You Can’t Easily Demonstrate Why Your Employees Are Competent

Imagine that an HSE inspector, customer auditor or your own management team asks:

“How have you established that the people carrying out this safety-critical activity are competent?”

Can you demonstrate the answer?

A robust system should be able to provide evidence of how competence requirements have been established and how individuals have been trained, assessed and monitored.

This does not necessarily mean producing an enormous quantity of paperwork.

It means being able to demonstrate a logical chain of assurance:

Risk → Role → Competence Requirement → Training → Assessment → Workplace Application → Review

For example:

Risk: Workplace vehicle movements

↓

Role: Banksman / Signaller

↓

Competence requirement: Understand vehicle movement risks, communication methods, positioning, reversing controls and site procedures

↓

Training: Appropriate Banksman/Signaller training

↓

Assessment: Knowledge and practical assessment

↓

Workplace application: Supervisor confirms competent performance

↓

Review: Reassessment or refresher training when appropriate

This provides much stronger assurance than simply recording:

“Banksman course – completed.”

HSE guidance recommends that employers identify training needs, ensure relevant and sufficient training is delivered, check that the necessary level of competence has been reached, check that training is applied, provide appropriate update/refresher training and retain training records. (HSE)

How Employers Should Review Their Health & Safety Training Programme

A comprehensive review does not need to be complicated.

Start by asking five fundamental questions.

1. What are the significant risks within our organisation?

Review your risk assessments and identify the activities where competence is particularly important.

2. Who needs to be competent?

Consider:

• Employees
• Managers
• Supervisors
• Plant operators
• Maintenance personnel
• Banksmen/signallers
• Lifting personnel
• First aiders
• Fire marshals
• Contractors
• Temporary workers
• Other safety-critical roles

HSE states that everyone working for an employer needs appropriate information, instruction, training and supervision, including contractors and self-employed people where relevant. (HSE)

3. What does competence actually look like?

Don’t simply identify a course.

Define the knowledge, skills and experience required to perform the task safely.

4. How will competence be demonstrated?

Depending upon the activity, this might include:

• Formal training
• Practical assessment
• Workplace observation
• Written or verbal assessment
• Supervisor assessment
• External certification
• Refresher training
• Periodic reassessment

5. How will you know the system remains effective?

Use:

• Accident and incident information
• Near-miss reports
• Audit findings
• Inspection findings
• Employee feedback
• Supervisor observations
• Customer feedback
• Competence assessments
• Training records
• Changes to equipment and processes

This creates a continuous improvement cycle rather than a one-off training programme.

Include the Workforce in Your Training Review

An effective training programme should also reflect the experience and needs of the people undertaking the training.

New employees, people changing roles, people taking on additional responsibilities and employees with particular training needs may require different approaches.

The HSE recommends that employers consider these groups when planning information, instruction, training and supervision. (HSE)

Training should therefore be:

• Relevant
• Understandable
• Practical
• Proportionate to the risk
• Appropriate to the individual’s role
• Supported by supervision and workplace application

This is particularly important when training a diverse workforce with different levels of experience, education, language ability and practical background.

How C&G Services Can Help

At C&G Services, we recognise that effective Health & Safety training is about more than putting employees on courses.

Our approach can support employers through the complete process of identifying training requirements, developing competence and reviewing effectiveness.

Depending upon your requirements, C&G can assist with:

Training Needs Analysis

We can help identify the Health & Safety knowledge and competence requirements associated with different roles within your organisation.

Competence Assessments

Where appropriate, practical and knowledge-based assessments can help establish whether employees can perform tasks to the required standard.

Bespoke Training

Training can be developed around your organisation’s actual processes, equipment, working environment and risks.

Refresher Training

We provide a wide range of refresher and update training across Health & Safety, construction, plant, lifting, transport and other operational disciplines.

Workplace Assessments

Competence can be considered in the context of the actual working environment rather than solely within a classroom.

Training Management

We can help organisations establish effective training arrangements, records and review processes.

Health & Safety Consultancy

Where training is only one part of a wider problem, C&G can provide consultancy support, including risk assessments, audits, inspections, management systems, process improvement and Health & Safety advice.

Our objective is to help employers develop a workforce that is not simply trained, but competent, confident and capable of applying safe working practices effectively.

Is It Time to Review Your Health & Safety Training Programme?

If you recognise any of these warning signs, it may be time to take a fresh look at your Health & Safety training arrangements.

Ask yourself:

✓ Do our certificates demonstrate competence – or simply attendance?

✓ Has our workplace changed since our training programme was developed?

✓ Are employees repeatedly making the same mistakes?

✓ Are we relying too heavily on qualification expiry dates?

✓ Can we demonstrate how we know our employees are competent?

If the answer to any of these questions is “I’m not sure”, a structured review could identify opportunities to improve your organisation’s approach.

The HSE’s guidance is clear that training should be relevant to the work, proportionate to the risks and supported by appropriate competence arrangements. Monitoring and review are important in establishing whether training remains relevant and effective. (HSE)

C&G Services can help you review your current arrangements, identify competence gaps and develop a practical training and assessment programme aligned with the risks within your organisation.

With experience across Health & Safety, construction, plant machinery, lifting operations, transport, civil engineering, manufacturing and other industry sectors, C&G can provide both the training and consultancy support required to help organisations develop a more effective approach to workforce competence.

To discuss your organisation’s training requirements or arrange an initial review, contact C&G Services (Europe) Ltd.

Telephone: 01453 826781
Email: [email protected]
Website: www.gettrained.co.uk