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emPower eLearning: January 2012

emPower eLearning

Saturday, January 28, 2012

The Flipped Classroom

The Flipped Classroom is an interesting concept in blended learning, focussing on literally 'flipping' the traditional model of education...

As Karl Fisch identified, regular homework requiring students to apply theory to problems/activities, highlights three groups;

  • A proportion who completed the work with no problems and who probably didn't need the practice
  • A second segment who wouldn't even attempt the homework (didn't want to; not enough time; lack of understanding)
  • A final group in the middle who would attempt the work, but become frustrated because they couldn't do it or had done it incorrectly.

So instead of 'lecturing' at the front of a class for an hour, this 'chalk & talk' 'transmission' element is recorded (short videos, podcasts, screencasts, etc) and given to students (on CD or online) to watch beforehand (or indeed afterwards). What would be homework i.e applying that information to problems, group work, etc, is now done in class - potentially overcoming the two 'problem groups' discussed above.

The original 'founders' of the Flipped Classroom suggests that 'flipping' increases Teacher to student, and Student to Student interaction, since 'the role of the teacher has changed from presenter of content to learning coach'. Having said that, and as Doug Belshaw highlights, it is based on certain assumptions about our education system in which "we've commoditised learning to such an extent that it's becoming indistinguishable from training".

To this, and many of his other points, I agree. We should challenge core assumptions about how we teach, and importantly, how we assess students. However, in the situation we are in today, I think the Flipped Classroom is a great idea: it could be the starting block for teachers to begin to innovate, and an opportunity to engage students through the VLE (Moodle), provide interactive online content, and free up class time to run more engaging and interactive classes. Subsequently, I think this can lead to increased personal interaction with students, increased formative feedback, and importantly, increased understanding and student satisfaction.

There are a number of services to help support this notion of the Flipped Classroom, whether that be existing videos from the Khan Academy (a library of over 2,700 videos covering everything from arithmetic to physics, finance, and computer science), YouTube or Open Content (i.e. free with some restrictions) from MIT OCW or the Open University's OpenLearn site. Closer to home, we have facilities to capture our own materials and make them available through the Institutional systems such as Equella or the Podcasting Server.

To give you a better idea on the Flipped Classroom, see the video below. The images I used above were also taken from an interesting infographic from Knewton.com.
I'd love to hear your thoughts, and for those interested in implementing this approach, I'd be happy to help. Also keep your eye open for training and posts about the benefits of using multimedia (video, podcasting, screencasts, etc), to enhance learning, teaching and assessment...

This article was originally posted at http://scieng-elearning.blogspot.com/2012/01/flipped-classroom.html


Wednesday, January 25, 2012

Public Citizen to OSHA: Enforce Labeling Law for Toxic Coal Byproduct

According to Public Citizen, workers using coal slag abrasive are exposed to dangerous levels of beryllium, which has been linked to cases of cancer. Coal slag abrasive coal slag abrasive to blast ship hulls, bridges and other metal structures in preparation for painting.

In a letter to OSHA Enforcement Director Thomas Galassi, the group demanded that OSHA enforce a law requiring manufacturers of coal slag abrasive to disclose that their product contains “dangerous” levels of beryllium.

“Workers have a right to know if they are being exposed to toxic chemicals,” said Justin Feldman, worker health and safety advocate with Public Citizen’s Congress Watch division. “But coal slag manufacturers are not indicating that their product contains cancer-causing beryllium. Some companies even have the audacity to market their product as non-toxic. OSHA needs to enforce the law and end this practice at once.”

OSHA’s right-to-know rules require manufacturers to disclose the toxic chemicals in their products if workers might be exposed to unsafe levels. According to Public Citizen, a number of studies have demonstrated that people working with the product are routinely exposed to levels of beryllium that exceed OSHA Training standards. Beryllium exposure causes lung cancer and chronic beryllium disease, a debilitating lung condition.

“OSHA’s enforcement staff has known about this issue for several months, and we are calling on them to do the right thing,” Feldman said. “Dozens of blasting workers die each year from beryllium exposure. If OSHA just enforces the rules that are already on the books, it will save lives.”

The letter is available at http://www.citizen.org/documents/Coal-Slag-HazCom-Memo.pdf.

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Tuesday, January 24, 2012

Understanding the Impact of eLearning & Distance Learning on Your Net Operating Profit

 When a learning professional is “STRATactical,” it implies that he or she fully understands the strategy needed to be successful as they tactically engage in behaviors to achieve success in the development and delivery of all learning services and products, with a keen understanding of the importance that eLearning and Distance Learning have on the financial success of an organization, while at the same time, building a learning legacy more influential than when they arrived at the organization.

Although learning professionals operate within a business structure, we have not been traditionally seen as business savvy or having much business acumen. However, if we can “walk the talk” of business operations -- acquire sufficient business acumen -- we will both portray and impact our organization’s financial growth and lend legitimacy to the administrative and operational functions learning brings to an organization.

As an example, when I retired from the FBI to begin my career in business, I was unprepared for the “language of business” to meet the challenges posed to me by CEOs, COOs and CFOs. I fully understood the goals aligned to the business strategy, however, I lacked an understanding of the business acumen and how to align a learning function with a business operations foundation. The road ahead meant I needed to embark on learning how a business functions and what the drivers are behind those functions.  My road led me to complete three years of courses in a Doctoral studies program in Business Administration. I needed to align learning and development (L&D) to the organization’s strategy and provide tactics to impact the business through L&D initiatives and programs. Fortunately, the learning technologies and tools were advancing as rapidly as my understanding of business operations, resulting in my passion for and belief in eLearning and distance learning as the key discriminators to affect the net operating profit of a business. These tools simultaneously provide learning opportunities that are on-demand, just-in-time, ready-to-learn, while they personally and professionally grow an audience of employees.

Not only are industries changing and disappearing, internal management functions are changing and some are disappearing as well. For the organization’s learning professional(s) to succeed, they must engage in an understanding of the functions within the business organization that are the heartbeat of business operations.  A professional colleague, Wally Adamchik, President of Be A Firestarter, recently advised me, “You may offer effort, but you are judged on results.”

Simply offering courses, whether they are instructor-led or eLearning, web-based or utilize distance learning, is not enough, learning professionals must clearly provide training to the business operations functions and they must do so with an eye on the business impact they can influence in learning outcomes and financial savings and revenue generation.  In short, learning professionals must not consider themselves as an administrative function, rather as an operational function to support their business.

Another professional colleague, Kevin Cope, President and CEO of Acumen Learning recently advised me, “If you can contribute to your company’s cash and cash flow, you’ll be valued as an employee who practices business acumen -- and you’ll help fuel the success of your business. Further, how much more effective would you be as leaders and decision makers by first knowing the key measures and then what the trend or change is of those numbers, the ‘why’ behind the changes and then identify how they can impact the number(s) within your individual role?”

Dick Davies, President of Sales Lab DC, advised me “….how quickly an attitude and behavioral change can trigger a significant performance improvement…[and] finding and implementing a skill or practice that improves performance is an important behavior…”  As reinforcement, Scott Eblin, author of The Next Level, has stated, “…we must abandon the behaviors that made us successful previously, and embrace new behaviors where different results are expected.

Acting STRATactically
I trust I have outlined a solid foundation to my belief that learning professionals must provide business impact to an organization through the development and delivery of learning services and products. So, where do you begin?

With an eye on the business impact, first look at developing a training needs analysis and decision matrix culminating in an enterprise training initiative aligned to business operation functions.  Ask yourself and ask business function leaders within your organization, “Which functions have the greatest impact on our business success? Prioritize those functions and choose the top three.  Start with the most important function and determine the roles within that function that are the wheels behind driving that function. There may be two, three, maybe ten or more, but establish the priority of those roles too. 

In discussing with the functional leader, determine:

1) who within that role is a subject matter expert (SME),
2) what is the voluntary turnover/resignation rate of employees within that role, and
3) what does that cost the business in dollars – which may include lost direct revenue, recruitment monies spent to find a replacement, time to train the new employee, etc.

Determine with the SME what courses related to that role are currently offered within the organization or through a vendor. Continue the discussion with the SME by asking if those are the courses needed to function within that role within the organization. There may be courses that are missing – it is now you are performing a training gap analysis. With the SME make a list of the requisite courses to function within that role – and identify them as basic, intermediate and advanced. Contact former employees within that role, those that voluntarily resigned, and ask them if this new list of courses, if offered, would have made a difference in their decision to leave the organization.  Now, with the SME and concurrence of the functional leader, prioritize the courses within that role that are required and develop those that are missing.  It is now you need to determine if an instructor-led (ILT) or eLearning (eL), web-based (WBT) or distance learning (DL) course is the correct way forward in closing the gap on training within that functional role.

To assist in your decision making whether to develop and deliver or purchase and deliver the course(s) as eL, WBT or DL, use the language of business – conduct a financial analysis and employ cost comparison methodology for staffing, development, delivery, production of course materials, costs of classroom space, multi-media, travel and per diem, record keeping, etc. Once completed, now you can return to the training analysis methodology and repeat for each role, within each function and you will have the financial information documented to justify your eLearning and distance learning approach to training within your organization.  And, when you proven your eLearning and distance learning approaches have improved bottom-line savings to corporate expenses, it will be time to turn your developed content into a revenue generation model which will improve top-line growth and the learning function will be recognized as a viable business operation within your organization.

Learning professionals who have kept pace with learning technologies and tools know that eLearning and distance learning capabilities deliver similar, if not more powerful, learning impact for the learner; now, armed with a training needs analysis approach and a cost calculation model, the road ahead is clear.  Lead by example – exemplify the behavior needed to focus on eLearning and distance learning to impact the net operating profit of your organization.

Alan A. Malinchak is the Chief Learning Officer at Homeland Security Solutions, Inc. (HSSI). Malinchak can be reached at malinchaka@homelandsecurityinc.com, or contact him through LinkedIn.
This article was originally posted at http://www.humanresourcesiq.com/corporate-learning-alignment/articles/understanding-the-impact-of-elearning-distance-lea/

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Thursday, January 19, 2012

For Digital Learning, the Devil’s in the Details

When former governors Jeb Bush and Bob Wise strode to the stage at the 2011 Excellence in Action National Summit on Education Reform in San Francisco last October, Sal Khan had just shown the 750 attendees his vision of the digital future.
Khan is the former hedge-fund analyst turned education rock star who started Khan Academy, a nonprofit that reaches millions through its free online lessons and assessments. Tools like these, said Khan, can catapult education from its time-based roots toward a competency-based model in which students progress upon actual learning—mastery—instead of seat time.
At the same conference a year earlier, the two former governors, cochairs of Digital Learning Now!, released “10 Elements of High Quality Digital Learning.” This year, Bush and Wise said they had evaluated each of the 50 states against the elements and explained the assessment methodology they had used: states were judged against 72 individual metrics. (Disclosure: I was one of many who provided feedback on how different states ranked on the criteria and serve as a “digital luminary” for the Digital Learning Now! effort.) Rather than announce where the states fell in the ranking, the governors gave the crowd a preview of their “Roadmap for Reform,” a guide to help states navigate different paths toward changing their online education policies (see sidebar).
With the road map in place, one might assume that moving into the future will be a straightforward exercise: the pieces are all there and model legislation is forthcoming, so state policymakers just have to enact the 10 Elements.
Of course, things are never so simple, and many questions remain.
Some questions reflect legitimate disagreement over Digital Learning Now!’s recommendations, even among those who agree with its broad vision. An obvious flash point will be the idea that states require students to take at least one college- or career-prep course online to earn a high school diploma.
One argument in favor of the requirement is that the outcome from taking an online course—gaining the skills to succeed in a digital environment and perhaps become more self-driven—is valuable in a world in which postsecondary education and workforce training are increasingly done online. Yet some see this as yet another input-based requirement in a system already overburdened with mandates, and in conflict with the spirit of digital learning: if the experience is so important or compelling, won’t students naturally flock to online learning, particularly given Digital Learning Now!’s recommendation that dollars follow students to the online course of their choice?
Another consideration is that elementary-school students don’t take courses—at least in the sense that high-school and middle-school students do—and so ensuring that elementary-school students have access to online learning at the course level seems to miss some fundamental principle. According to the state report cards, though, several states have achieved their goals at the elementary-school level, which only raises more questions.
Many of the pieces that Digital Learning Now! casts as critical to the endeavor are not yet in place, and therefore no one actually knows how they will work in practice. For example, Digital Learning Now! has hitched its wagon to the enactment of the Common Core standards and accompanying next-generation assessments that should be in place by 2014. Whether these assessments will facilitate a competency-based learning environment unburdened by time—or lock in today’s system—is yet to be seen. States may abandon the digital effort when they see the up-front costs of implementing an online assessment system. And if they do, what will that mean for a plan that rests on paying for achievement instead of seat time? Valid, reliable, authentic, on-demand, and independent assessments are critical to moving to a system based on student learning outcomes. What about those courses that don’t fall under the Common Core? Does an outcome-based funding system require extending the Common Core to all subject areas, or will states create unique standards for subject areas other than math and English? Could entrepreneurs develop competency badges for their students that the public would recognize as legitimate? How would such competency measures be accredited?
A number of operational challenges need to be worked out as well. Utah, for example, passed in the spring of 2011 Senate Bill 65, based on the 10 Elements of High Quality Digital Learning. Utah state senator Howard Stephenson declared that the bill ends the “tyranny of time and place” in education by allowing dollars to follow high school students to their online course of choice. The legislation calls for the state to withhold 50 percent of the provider’s fee until the student successfully completes the course.
Not surprisingly, the devil has been in the details. Crafting a viable funding model for online courses that makes sense for districts and providers alike has not been easy. Even more challenging is helping schools and districts transition to a world in which students still need some of the services they provide but take most of their courses online. How does funding work in this model? How do schools create the flexible schedules and offer the critical services—many of which may be nonacademic—to accommodate students’ varying needs? How do they transition to this service—or community center—model?
A related set of issues plagues the funding model from the state’s fiscal perspective. If students progress based on competency instead of cohort, the state should presumably reward schools and providers that help students progress faster. And Digital Learning Now! suggests that it should reward those providers that help students make the most growth. Set aside for a moment the demands on state data systems created by an outcome-based system that rewards growth and the fact that these systems are not in place today. If this policy were in place, the state would be on the hook for paying for a student who masters, say, 20 half-semester courses in a given year, rather than a more conventional 12 or 14. How will states deal with this fiscal uncertainty? Holding back students seems like a poor choice, as does punishing schools that can educate students faster with less revenue.
And what if a student masters the high school curriculum by the time she is 15, as many students undoubtedly could? Does she go to college? Does she take time off? Or does she stay in high school with her friends but take college courses? If so, who pays?
Suggesting that a road map document could tackle such complexity isn’t fair. But a glimpse into the exciting— and uncertain—future presented by Digital Learning Now! does raise many legitimate questions. That’s no reason to delay implementing its recommendations though; innovation is never perfect right out of the box. Iteration in practice is critical. With the “Roadmap” coming on the heels of Khan’s conference presentation, surely some in the audience wondered whether innovations yet to come might even clear away many of the familiar roadblocks.

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Monday, January 16, 2012

10 Things Chemical Plant Operators Need to Know About OSHA's New Chem NEP

OSHA announced the launch of its PSM National Emphasis Program for chemical facilities (Chem NEP). The new Chem NEP expands nationwide a previous 2009 Pilot Chemical Facilities Process Safety Management NEP, which had covered only a few OSHA regions, and established policies and procedures for inspecting workplaces covered by the PSM Standard.

The inspection process under the new Chem NEPincludes detailed questions designed to gather facts related to PSM requirements and verification that employers' written PSM programs are adequately implemented in the field. The intent of the NEP is to conduct focused inspections at facilities randomly selected from a list of worksites likely to have covered processes. The director of OSHA, Dr. David Michaels, announced at the launch of this new NEP that during "the pilot Chemical NEP, [OSHA] found many of the same safety-related problems that were uncovered during our NEP for the refinery industry … As a result, [OSHA is] expanding the enforcement program to a national level to increase awareness of these dangers so that employers will more effectively prevent the release of highly hazardous chemicals."
Below are the 10 most important things chemical plant operators need to know about the new nationwide Chem NEP:
1. It is effective immediately and has no expiration.
Programmed inspections will begin immediately in all regions. Unlike the Refinery PSM NEP and the Pilot Chem NEP, this directive does not include an expiration date.
2. It expands the Chem NEP nationwide.
Whereas the pilot NEP involved only a few select regions under federal OSHA’s jurisdiction, the new nationwide Chem NEP applies to all OSHA regions. And unlike the pilot chem and refinery NEPs, states are requiredto participate in this emphasis program. If the approved state OSHA plan already has some version of a Chem NEP or wants to implement its own version (within 60 days), the state plan must demonstrate to federal OSHA that its program is at least as effective. Otherwise, the states must adopt this directive.

3. Targets for Chem NEP inspections include:
The types of workplaces inspected under the new Chem NEP are similar to the pilot. OSHA will assemble a master list for each region based on employers who: (1) submitted Program 3 Risk Management Plans to EPA; (2) have a NAICS code for Explosives Manufacturing; (3) appear in OSHA’s enforcement database as having been cited in the past for PSM-related issues; and (4) are known to the area office as operating a PSM-covered process. Any workplaces selected for inspection under OSHA’s Site-Specific Targeting Plan, which also happen to operate a PSM-covered process, will be inspected under the Chem NEP directive. Likewise, inspections arising from an employee complaint, referral or incident involving a PSM issue also will be conducted under the Chem NEP directive. Complaints, referrals and incidents unrelated to PSM may still result in an inspection under this directive at the area director’s discretion.
VPP- or SHARP-approved facilities are partially exempt. (They are exempt from programmed inspections, but may be subject to inspection under the Chem NEP upon an employee complaint, incident or referral related to PSM.) 

4. The selection of unit(s) includes:
OSHA will attempt to identify “the most hazardous process” as the selected unit(s) for inspection under the Chem NEP. The selection of the unit(s) will be based on the following:
· Quantity of chemicals in the process;
· Age of the process unit;
· Number of workers and/or contractors present;
· Incident and near-miss reports and other history;
· Input from the union or operators;
· Ongoing maintenance activities; and
· 119(o) Compliance Audit findings.

5. Inspection scheduling expectations include:
Every OSHA area office across the country is expected to complete 3-5 programmed Chem NEP inspections per year. The sites selected for inspections will consist of approximately 25 percent workplaces that use ammonia refrigeration and 75 percent all other workplaces with a PSM coverage process. 

6. It emphasizes implementation over documentation.
Like the pilot NEP, compliance officers will be focused on implementation of PSM elements in the field rather than relying solely on the quality of the written PSM program.
7. It features dynamic list questions.
Like the pilot NEP, the dynamic list-based evaluation under the Chem NEP is a mandatory gap analysis formatted in a series of questions to facilitate evaluation of compliance with various elements of the PSM standard. The list of questions rotates periodically and will not be publicly disclosed. The questions are accompanied by guidance for CSHOs as to what documents to request, interview topics and questions to cover, and potential citations to issue. Each dynamic list includes 10-15 primary and 5 secondary questions. Questions are designed to elicit a “Yes,” “No” or “N/A” determination of PSM compliance, and any “No” will normally result in a citation.

8. The following documents and presentations will be requested:
During a Chem NEP inspection, employers will be asked to produce the following documents:
· List of PSM-covered processes;
· List of units and maximum intended inventories;
· Three years of OSHA 300 logs for employer and contractors, and contract employee injury logs; 
· Summary description of PSM program;
· PFDs, P&IDs, Plot Plans and electrical classification drawings for the selected unit(s);
· Description of process and safety systems, safe upper and lower operating limits and design codes and standards for the selected unit(s);
· The initial PHA and the most recent Redo or Revalidation for the selected unit(s) (including PHA reports and worksheets, recommendations and action items and schedule for addressing and completing recommendations and action items); and
· PSM incident reports for the selected unit(s).
Before a walkaround inspection, OSHA will request the following presentations:
· Overview of the company’s PSM Program and how it is implemented;
· Identify personnel responsible for implementing each PSM element;
· Description of records used to verify compliance; and
· Process description for the selected unit(s).
9. A single issue will yield multiple citation items.
As we reported about the refinery NEP, OSHA was turning a single issue into multiple violations. The agency has memorialized this practice in the Chem NEP directive. The directive advises CSHOs that a single valve change, for example, could implement 11 different PSM elements, and each should be considered for individual citation items.
10. Abatement verification and documentation is now mandatory.
Under the pilot NEP, some citations required employers to simply certify that abatement had been completed. Under the new Chem NEP, however, abatement verification and documentation is now mandatory. The NEP also directs CSHOs to review past PSM-related citations issued to the same employer going back 6 years, and identify potential failures to abate and possibly repeat and willful violations.

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Thursday, January 12, 2012

HIPAA Electronic Transaction Standards Make Progress

Claims processing standards expected to cut administrative burden on healthcare providers, insurance companies, and states, says Department of Health and Human Services.

The Department of Health and Human Services (HHS) has issued an interim final rule that prescribes operating standards for electronic fund transfers (EFT) and electronic remittance advice (ERA)--the payment explanation that gives details about providers' claims payment. Last July, HHS released standards for insurance eligibility and claims status transactions.

Required by the Health Insurance Portability and Accountability Act (HIPAA), these operating rules are expected to cut $16 billion from the administrative costs of healthcare providers, insurance companies, and states over the next 10 years. HHS anticipates that the EFT and ERA rules alone will save up to $4.5 billion.

Currently, health plans send providers electronic payments separately from electronic remittance advice. Physician practices and hospitals use the ERAs to post the payments in their financial systems, but cannot link those postings automatically to the funds transfers. Under the new rules, a trace number will allow providers to link the two transactions, eliminating the time and expense of manual reconciliation.

Cindy Dunn, a senior consultant at MGMA Consulting, told InformationWeek Healthcare that the need to manually connect funds transfer with remittance advice imposes a significant burden on physician practices. So the new regulation will help them, she said.

The same is true for hospitals, said Doug Hires, a health IT consultant who is a partner in Santa Rosa Consulting. Because ERAs are often sent days or weeks before funds are transferred, he said, it's especially troublesome to "re-associate" the two transactions manually. Consequently, he said, the new regulation "is a big deal for hospitals."

However, he added, some coordination and testing will be required to implement the new operating rules, just as with the new HIPAA 5010 transaction set. "There's going to be some modification of systems and processes. Hopefully, the benefits are going to far outweigh the costs of these changes."

While the regulation goes into effect immediately, health plans have until Jan. 1, 2014 to implement the new EFT and ERA standards. They must use the operating rules for eligibility and claims status by Jan. 1, 2013. This will require both payers and vendors of billing systems to update their software, but that wasn't unexpected, Dunn noted.

The Committee on Operating Rules for Information Exchange (CORE), a branch of the Council for Affordable Quality Healthcaare (CAQH), which includes insurers and other industry stakeholders, has developed many of the operating rules for HHS. CORE worked with the Electronic Payments Association, a banking group, to create the EFT and ERA standards.

The Patient Protection and Affordable Care Act requires HHS to write regulations that implement the HIPAA-mandated operating rules over a five-year period ending in 2016. Besides the two interim final rules it has already issued, HHS plans to issue further administrative simplification rules that address:

-- A standard unique identifier for health plans,
-- A standard for claims attachments, and
-- Requirements that health plans certify compliance with all HIPAA standards and operating rules.

In its announcement of the new regulation, HHS cited a 2010 study in Health Affairs that found physicians spend nearly 12% of their revenue from patient care on administrative tasks, including billing and collection. Researchers estimated that simplifying these systems could save four hours per week of professional time per physician and five hours of support staff time every week.

"As a nurse, I know the importance of giving healthcare professionals time to focus on patient care," said Marilyn Tavenner, acting administrator of the Centers for Medicare and Medicaid Services (CMS). "The less time a physician has to spend on paperwork is that much more time that can be devoted to patient care. Having standardized procedures across the healthcare industry can only lead to lower costs and greater efficiencies all around."

When are emerging technologies ready for clinical use? In the new issue of InformationWeek Healthcare, find out how three promising innovations--personalized medicine, clinical analytics, and natural language processing--show the trade-offs. Download the issue now. (Free registration required.)

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A Classroom with Difference: A Whole New World of Learning!

The article talks about flipped classroom, flipped model, flipped learning model. It is of help for those who want to learn about what is elearning, online learning, and flipped learning, etc all about.

Learning in the flipped classroom is something that happens if the learner and / or teacher go against the traditional chalk and talk method, a mind-numbing methodology that has been inflicted for generations on unsuspecting students.

The flipped model has been much talked about in learning circles. Such circles have now come to include and accept ‘learners’ as active participants in the learning process. It essentially depends on using the new technologies to make learning interactive and interesting through the endlessly experiment media. The model seeks to provide a self-paced learning experience to the learner, in effect a ‘tailored’ one so that the learner may delve deeper into topics. The subjects / topics are of interest to him/her or spend more time on a particularly difficult one. Sounds amazing! Some may even rue the fact that they were born much earlier and being unable to take advantage of this newer system sweeping across the learning community.

Why, there may come a time when schools are no longer necessary and the learner “thinks’ his PC or tablet or some other gadget ‘on’ and chooses his / her learning for the time. No school buildings, no principal, no teachers and the least of all no punishments or social ostracism! The resultant tax savings may be channeled to other pressing needs or even subsidizing the studies of a ‘needy’ learner.

One may be forgiven for thinking that all this is fine for affluent societies, what about the millions who are in that part of the world where the required stuff is not available? Remember there was limited internet before the 1990s and yet societies have developed!

Some doubters still question this flipped learning model but these are in an increasing minority (their fear stems from having to relearn or come down from their pedestal of the ‘omniscient’ one).

About emPower 

emPower  is a leading provider of comprehensive Healthcare Compliance Solutions through Learning Management System (LMS). Its mission is to provide innovative security solutions to enable compliance with applicable laws and regulations and maximize business performance. empower provides range of courses to manage compliance required by regulatory bodies such as OSHA, HIPAA, Joint commission and Red Flag Rule etc. Apart from this emPower also offers custom demos and tutorials for your website, business process management and software implementation.

Its Learning Management system (LMS) allows students to retrieve all the courses 24/7/365 by accessing the portal. emPower e-learning training program is an interactive mode of learning that guides students to progress at their own pace.

For additional information, please visit http://www.empowerbpo.com.

Media Contact (emPower)
Jason Gaya

12806 Townepark Way
Louisville, KY 40243-2311
Ph: 502 -400-9374

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Tuesday, January 10, 2012

Use OSHA’s Compliance Directive to Evaluate your PPE Program

You invest a lot of time, effort and money in your personal protective equipment (PPE) program, so you want to be sure you’re meeting OSHA’s expectations.

OSHA’s PPE compliance directive, 29 CFR Part 1910, Subpart I, Enforcement Guidance for Personal Protective Equipment in General Industry (CPL 02-01-050), establishes OSHA’s general enforcement and guidance policy for its PPE standards. It instructs OSHA enforcement personnel on both the agency’s interpretations of those standards and the procedures for enforcing them. You can review the directive for insight on how compliance officers will evaluate your PPE program.

OSHA recognized that recent changes to PPE rules needed clarification to ensure that its enforcement efforts were consistent.

OSHA published a revision to the general PPE requirements at §1910.132 in the April 6, 1994, Federal Register. This revision:

➤ Required employers to select appropriate PPE based on the hazards present or likely to be present in the workplace,

➤ Prohibited the use of defective or damaged PPE and

➤ Established employee training requirements.

This action was followed on Nov. 15, 2007, with the publication of the final rule for employer payment for PPE. A revision in the Sept. 9, 2009, Federal Register updated references to applicable national consensus standards to recognize more recent editions of the standards. On June 8, 2011, OSHA removed the written training certification requirements.

The PPE directive, CPL 02-01-050, took effect on Feb. 10, 2011.

Hazard Assessment

OSHA compliance safety and health officers (CSHO) will ask to see your written certification that a hazard assessment has been conducted and will issue a citation for a violation of §1910.132(d)(2) if there is no written certification. Appendix B of 29 CFR Part 29 Subpart I provides guidance on how to conduct the hazard assessment.

You can rely on a hazard assessment conducted by a previous employer provided that the job conditions and hazards have not substantially changed. If you rely on a previously conducted hazard assessment, the certification must contain the date you determined it was adequate, rather than the date of the actual assessment.

Citations for violations of the hazard assessment requirements at §1910.132(d)(1) will pertain only to eye and face, head, foot and hand protection. The directive clarifies that if another OSHA standard has more specific assessment and selection provisions, then CSHOs will issue citations for violations of the more specific standard. For example, there are PPE hazard assessment and selection requirements in the standards for respiratory protection, permit-required confined spaces, hazardous waste operations and emergency response and bloodborne pathogens.

PPE Selection, Fit and Use

The Sept. 9, 2009, revisions to the PPE standards adopted more recent editions of applicable national consensus standards. The directive instructs CSHOs to cite the standards for the use of eye and face protective devices (§1910.133(b)), head protection (§1910.135(b)) and foot protection (§1910.136(b)) if the PPE selected and provided by the employer doesn’t meet the American National Standards Institute (ANSI) or ASTM International (ASTM) standards incorporated by reference in those standards.

However, a citation won’t be issued if the employer demonstrates that a piece of equipment is as effective as that which complies with the incorporated standard. In the preamble to the Sept. 9, 2009, final rule, OSHA stated that this provision for equivalent protection “allows employers to use subsequent national consensus standards that they can demonstrate provide the requisite level of employee protection.” And in the preamble to the proposed rule published on May 17, 2007, OSHA stated: “OSHA has examined the standards for eye and face, head and foot PPE issued by ANSI and ASTM International (ASTM) over the last 40 years. OSHA has found that these standards reflect the state of the art in terms of design safety that existed at the time they were issued. Furthermore, each successive edition of these standards has improved the design features of the PPE.”

Make sure PPE fits properly. You can be cited for a violation of §1910.132(d)(1)(iii) if your PPE doesn’t properly fit each affected employee. Appendix B of 29 CFR Part 29 Subpart I provides non-mandatory guidance for determining and achieving the proper fit. The appendix includes the following:

“5. Fitting the device. Careful consideration must be given to comfort and fit. PPE that fits poorly will not afford the necessary protection. Continued wearing of the device is more likely if it fits the wearer comfortably. Protective devices are generally available in a variety of sizes. Care should be taken to ensure that the right size is selected.

“6. Devices with adjustable features. Adjustments should be made on an individual basis for a comfortable fit that will maintain the protective device in the proper position.”

The key to avoiding a citation for allowing the use of defective or damaged PPE (a violation of §1910.132(e)) is to ensure that, in its present condition, the PPE provides the protection it was designed to provide. When PPE is required, you can allow an employee to voluntarily use PPE that he already owns, but you remain responsible for ensuring that this PPE is not defective or damaged.

If you fail to communicate your PPE selection decisions to each affected employee or fail to conduct PPE demonstrations, you risk a citation for a violation of §1910.132(d)(1)(ii).

Employee Training

OSHA wants employees to fully understand their use of PPE. During an inspection, the CSHO will make sure you’ve trained each employee on the following:

➤ When and what PPE is necessary;

➤ How to don, doff, adjust and wear the PPE;

➤ The limitations of PPE; and

➤ The proper care, maintenance, useful life and disposal of PPE.

The training requirements apply when PPE is used to protect the eyes and face, head, feet and hands. Failure to meet these requirements can bring a citation for a violation of §1910.132(f)(1)(i)–(v).

The CSHO will observe your employees and ask them questions to determine whether each employee who performs work requiring the use of PPE can demonstrate an understanding of the required training and the ability to use the PPE properly. You can be cited for a violation of §1910.132(f)(2) if you fail to meet the training requirements.

Refresher training isn’t required annually or on a set schedule, but be sure to retrain each affected employee when changes in the workplace or in the types of PPE used have made previous training obsolete. CSHOs will cite §1910.132(f)(3) when they discover a lack of necessary refresher training.

The directive indicates that OSHA does allow you to depend on training provided by a previous employer. In this case, the CSHO won’t issue a citation for a training violation if he determines the employee has the requisite knowledge and skill through his or her prior experience.

The directive includes provisions for citing the employer for not having a written certification of training. However, the certification requirement was deleted in a final rule published in the Federal Register on June 8, 2011. You no longer need to have a written certification of PPE training.

Employer Payment

Perhaps the most contentious revision to the PPE standards is the requirement for employer payment. This topic also raises the most questions on OSHA’s expectations.

In general, when PPE is required, you must provide it at no cost to your employees. In enforcing these requirements, CSHOs will first establish the existence of an employer-employee relationship.

The nature and degree of control asserted over the work is one of many factors in the employer-employee relationship. Other factors include the level of skill required, the location of the work, the duration of the relationship between the parties, the method of payment, the individual’s role in hiring and paying assistants, whether the work is the regular business of the employer, the provision of employee benefits and the tax treatment of the individual. A truly self-employed “independent contractor” is not considered to be an “employee” in regard to PPE payment requirements. CSHOs carefully will scrutinize the nature and degree of control asserted over employees involved in day-to-day activities to determine whether they are, in fact, independent contractors.

When you do provide and pay for appropriate PPE necessary to protect your employees, you don’t have to pay for upgraded PPE that an employee wants to provide for his own use. However, if you decide to select and provide PPE that goes beyond OSHA’s minimum requirements, the directive indicates that you have to pay for the “upgraded” PPE.

Exceptions from Payment Requirements

There are exceptions to the payment requirements. For example, you don’t have to pay for non-specialty safety-toe protective footwear or non-specialty prescription safety eyewear if you allow the employee to wear it off the job site. You do need to provide and pay for appropriate non-prescription safety eyewear for the employee, and if specialty prescription eyewear, such as inserts for a respirator facepiece, is necessary, you must pay for it. If metatarsal guards are necessary, you don’t have to provide and pay for safety footwear with built-in metatarsal protection if you provide, at no cost to employees, metatarsal guards that can be attached to the outside of the shoe or boot.

The directive addresses questions that arise concerning workers’ clothing. Long-sleeved shirts, long pants, street shoes and ordinary fabric or leather work gloves may help employees avoid workplace injury and have protective value; however, at §1910.132(h)(4)(ii), this type of clothing is excluded from the payment requirements.

In addition, under §1910.132(h)(4)(iii), you don’t have to pay for ordinary clothing, skin creams or other items used solely for protection from the weather such as winter coats, jackets, gloves and parkas that employees normally would wear to protect themselves from the elements. However, you must pay for clothing needed for protection from unusually severe weather conditions. In addition, clothing used in artificially-controlled environments with extreme hot or cold temperatures, such as freezers, is not considered part of the weather gear exception.

The directive includes two tables to explain the payment requirements:

➤ Examples of PPE for which Employer Payment is Required When Used to Comply with an OSHA Standard and

➤ Examples of PPE and Other Items Exempted from the Employer Payment Requirements.

Paying for Replacement PPE

You must provide replacement PPE at no cost to the employee except when the employee has lost or intentionally damaged the PPE. This exception even applies if it’s a single instance of lost PPE. The directive states that you can consider PPE to be lost if the employee comes to work without it.

To cut down on lost PPE, the directive clarifies that you may require the PPE you’ve provided to remain at the work site in lockers or other storage facilities. If you do allow employees to take PPE off of the job site, you still initially must provide the required PPE at no cost to employees. In addition, the rule doesn’t prohibit you from sending employees home to retrieve the PPE or from charging an employee for replacement PPE when the employee fails to bring the PPE back to the workplace.

If you do allow an employee to voluntarily use appropriate PPE that he already owns, you cannot force the employee to also provide his own replacement PPE. When it’s time to replace employee-owned PPE, it’s likely that you’ll provide and pay for it.

PPE Policies

You’re free to develop and implement workplace rules, such as reasonable and appropriate disciplinary policies, replacement schedules and allowances, to ensure that employees have and use the PPE you’ve provided.

The directive includes many sample citation scenarios for violations of the employer payment requirements, and it has a section on PPE payment questions and answers that you may want to review.

PPE probably is a large part of your safety budget. The use of PPE readily is apparent during an OSHA inspection, and CSHOs are concerned that it’s being used properly. Recent changes to PPE rules have prompted OSHA to update the instructions that CSHOs follow when they evaluate compliance with PPE requirements. You can consider these same instructions as you implement your PPE program. OSHA’s compliance directive, 29 CFR Part 1910, Subpart I, Enforcement Guidance for Personal Protective Equipment in General Industry (CPL 02-01-050) is available on OSHA’s Web site at http://www.osha.gov/OshDoc/Directive_pdf/CPL_02-01-050.pdf.

This article was originally posted at  http://ehstoday.com/ppe/osha-comp-ppe-0112/

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