September 9, 2021 / Roseanne Bottone

What the Most Effective Trainers Won’t Tell You

Sponsored by Lion Technology

If you attend workplace health and safety, hazardous materials, or environmental compliance training regularly, you have probably heard a question answered this way at least once: “Trust me. That’s what the regulations say.”

You won’t hear “trust me” from experienced, effective trainers very often. Here’s why: the answer "trust me" implies that the student should follow instructions without understanding the nuances of a rule, the rule’s intent, or how the rule was developed.

Industry regulations are dense, complex, and self-referential. They are often written in confusing government language. Knowing what the regulations say does not ensure success—it’s only a first step.

To make informed decisions, industrial hygiene professionals need knowledge and skills to navigate, interpret, and apply regulations to real-world situations.

When faced with difficult questions, the most effective trainers don’t answer with “Trust me.” They deliver a learning experience that prepares professionals to solve compliance challenges independently.

Four Ways Effective Trainers Answer Questions

To gather data on how experienced trainers answer questions, I informally polled individuals who, like me, are instructors with Lion Technology, a leading provider of regulatory compliance training. Together, the instructors I spoke with train thousands of professionals every year on topics like hazardous materials transportation, hazardous waste management, and OSHA’s hazardous waste operations and emergency response (HAZWOPER) standard.

Here are four ways these experienced trainers provide meaningful answers to difficult compliance questions.

1. "Let’s look together at the exact wording used in the regulations. That subject is found in… "

    Regulations can be like an inkblot test. Two people might read the same words, in the same order, and come away with wildly different interpretations. An effective trainer should be able to locate the regulation so that the group can dissect it together and determine how it applies to a specific activity or situation.

    2. "The [name of federal agency or department] answered a similar question in a guidance document or letter of interpretation. I can find you a copy of that."

      Because the text of the regulations can be unclear, agencies commonly use guidance documents to clarify the intent of specific rules and sometimes spell out how to comply. Often, regulated persons and industry groups contact agencies to request clarification of specific rules. The letters of interpretation that agencies write in response to these questions can provide insight into their thought process. That said, each letter applies only to the individual facility and the specific situation it addresses. They are not legally binding and do not supersede the regulations.

      3. "Rulemaking preambles in the Federal Register can help explain [name of agency or department]'s intent and choice of wording.”

        The background text of a final rule typically explains the rule’s purpose, intent, and implementation. In the preamble to a rule, agencies often respond to public comments and provide other useful information that can help stakeholders understand the regulation’s impact. The best training providers give you reference materials that include citations and source notes to let you research compliance topics in a targeted, informed way.

        4. "I’m not sure. Can you give me a chance to investigate and get back to you?"

          Even the most effective trainers are human. They may seem like walking encyclopedias of regulatory knowledge, but they don’t memorize every word of the regulations. Now and then, a student voices a question or circumstance the instructor has never encountered before.

          Experienced trainers love when this happens: it gives them an opportunity to enhance their knowledge and provide students with researched, accurate answers.

          Discover more techniques experienced trainers use to answer challenging questions in the expanded feature on Lion.com.

          Roseanne Bottone

          Roseanne Bottone is an instructor with Lion Technology and has 20 years of experience delivering regulatory compliance training. She holds a B.S. degree from Cornell University’s College of Agriculture and Life Sciences in Education and an MBA from C.W. Post

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