Employee training has always posed challenges for food companies. Consider language, for example. English may be a second language for many employees, which raises the issue of worker comprehension. Do employees really understand the concepts and procedures being taught, particularly the importance of product safety?
No less significant is the evaluation of worker competence based on understanding of the material covered in training. Some companies do not test their employees to verify comprehension of training content. Other companies may limit test score requirements to pass or fail because of liability fears based on union contracts or other potential litigation. This reasoning continues despite the introduction of sophisticated technological tools that can effectively deliver training and accurately determine worker comprehension.
In fact, the issue of employee testing to confirm comprehension has ramifications that extend far beyond the company. The most obvious one is public health, which can be jeopardized through improper food processing, packing, and shipping by workers who were conceivably taught but may not have fully understood company procedures, health standards, and safety requirements. The other is failure to comply with tightening training standards set by the Occupational Safety and Health Administration (OSHA).
To assume that an employee successfully completed training based solely on a pass/fail standard or the achievement of an arbitrary and barely passing grade is to invite trouble. It represents an unacceptable level of risk to the public, a possible OSHA investigation that could result in fines, and the litigation that would inevitably result. This is why food manufacturers, processors, and distributors need to understand the necessity of measuring employee comprehension and why nothing less than a 100% correct score earned by each employee should be considered acceptable. After all, how else can employers possibly know how much their employees don’t really understand?
Testing to confirm training comprehension is still relatively new to the food processing industry—so new that there are few if any hard and fast requirements from the U.S. Department of Agriculture (USDA) or the U.S. Food and Drug Administration (FDA). If there is any source for guidance on testing and comprehension that might be satisfactory to regulatory agencies, it is likely to be found among regulations promulgated by OSHA. The agency requires training to be tailored to the language, vocabulary, and education level of workers, which could be an issue for plants with many employees for whom English is a second language. As with OSHA, third-party audits such as good manufacturing practices (GMP) and the Global Food Safety Initiative (GFSI) demand verification that workers fully comprehend what they’re being trained to do.
Just imagine the ramifications when testing standards and acceptable scores are left up to the individual plant. This practice may well be the root of a problem bound to surface. Worker training and testing for gauging comprehension seems to be a hodgepodge of approaches that depend on company policies, most of which are likely to produce unacceptable results. Some plants, for example, eschew formal testing by deferring to on-the-job training and verbal corrections by supervisors with no formal process for documentation of comprehension (e.g., “Go stand next to Joe and do what he does.”). A few facilities are known to be using outdated training materials, including VHS tapes probably recorded at least two decades ago. More up to date, but equally ineffective, are lengthy PowerPoint presentations overloaded with text and presented in language that may be beyond the comprehension of workers with limited education, even those for whom English is their primary language.