Safety in Any Language

Feb 11, 2016, 13:48 PM
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January/February 2016

Employers must ensure all workers understand safety training, signage, and instructions regardless of their English proficiency.

By Megan Quinn

At one Midwestern scrapyard, two employees found themselves at odds over a simple problem: A broken electrical cord on a fan needed to be rewired. The worker who noticed the damage told his supervisor, but days passed and nothing happened. That’s because neither one was completely sure what the other had said. The worker spoke mostly Spanish, while his supervisor spoke mostly English. Finally, a bilingual employee, who was attending an on-the-floor safety training as an interpreter, explained the problem. Once the supervisor understood, he quickly assigned the appropriate worker to fix the cord.

When scrapyard employees have different levels of English proficiency, misunderstandings and miscommunications are common risks. Businesses that hire workers with limited English skills say they handle communication hurdles through a variety of creative approaches and a commitment to finding language-based resources that will ensure workers understand safety training and communications essential for their well-being.


Mark Lotzkar’s Vancouver, British Columbia, scrap­yard is many miles away from the Midwestern yard with the broken cord, but he is no less familiar with the challenges—and benefits—of having a language-diverse workforce. On any given day, the people who clock in at Pacific Metals Recycling International, where Lotzkar is the president and general manager, might speak Burmese, Chinese, Egyptian, Portuguese, Polish, Punjabi, Vietnamese, or Spanish. “They all speak English in various levels of competency. Some speak very little [English] and need an interpreter, and others are pretty darn good,” he says.

Lotzkar says the company uses multilingual safety signage, translation services, and know-how from bilingual employees to make sure everyone stays safe on the job and understands the hazards of working at a scrapyard. Regardless of the employees’ native languages, they all need and deserve to be informed, and it is up to employers to make sure that happens, he says. “Vancouver is a cultural mosaic for pretty much every nationality in the world. Because of that, we definitely have to be aware [of possible language differences] when we are hiring people … because we’re open to hiring whoever fits the job description.”


There is no official rulebook for how best to ensure employees with limited knowledge of English can understand and communicate regarding safety. Deciding what methods to use depends on the level of your employees’ fluency, their reading and writing abilities, and the complexity of the subject matter. “Everyone is going to need something different,” he says.

Legal Obligations

In the United States, the Occupational Safety and Health Administration requires that employers present safety training “in a manner that employees can understand” and verify that employees have actually understood the training. As OSHA Assistant Secretary David Michaels explains in a 2010 letter, “Employers are expected to realize that if they customarily need to communicate work instructions or other workplace information to employees at a certain vocabulary level or in a language other than English, they will also need to provide safety and health training to employees in the same manner.”

For example, if an employee has a limited vocabulary, your training must account for that. If employees are not literate in the language you use for training purposes, telling employees to read the training materials doesn’t count as providing effective training, Michaels says.


Businesses can do several things to improve communications during safety training as well as during everyday work activities, says Mark Lies, a partner with the law firm Seyfarth Shaw who trains clients on OSHA compliance issues. If employees receive their work instructions in languages other than English, Lies says, consider providing safety training in those languages, too. You also might want to enlist the help of bilingual employees or hire interpreters for official training sessions to overcome communication problems. Adding visual materials, such as pictograms and photos, also helps, he says.

In many cases, OSHA requires employers to verify that their employees understand the content of the safety training. Lies says recyclers should consider incorporating practical tests into the training, such as hands-on exercises or a multi-question quiz, to assess workers’ comprehension.

Maintain detailed documentation of employee training, Lies recommends, including copies of any practical tests employees have taken. Alternatively, you can have your employees sign a written statement that they have received and understood specific safety training. This document can be in either your employees’ first language or English, in which case someone can read it to workers in the language they best understand, he says. This documentation is important during an OSHA inspection to show proof that all workers have not only gone through safety training, but understood it, he says.


Tamara Deiro, director of safety for SA Recycling (Orange, Calif.), says her company has used some of these techniques to verify that employees are absorbing safety training and putting it into practice. Of SA’s approximately 1,200 employees across more than 45 facilities in California, Nevada, Arizona, and Texas, between 65 and 70 percent speak Spanish as their first language, she says. SA has spent the last few years improving its safety curriculum to give Spanish-speaking employees a better understanding of the training. Most of the company’s supervisors are bilingual, so when they go through training or learn about new safety issues, they can pass along that information in the language that fits their employees’ comprehension level, she says.

SA recently started testing employees in writing after most of their safety training sessions, and as a result, both English- and Spanish-speaking employees seem to have improved their knowledge, she says. “We come up with our own questions in both English and Spanish, and [employees] have to get a score of 70 or higher, showing us they understand it”; otherwise the employee must do the training again, she says.


At Pacific Metals, Lotzkar says managers verbally ask a set of specific questions to test employees’ knowledge before they leave the training room. “When you ask pointed questions, it becomes pretty clear when someone doesn’t get it,” he says. Managers also follow up with employees later on. If they see someone doing something that contradicts the safety training, they will discreetly approach the employee and go back over the errors to avoid singling workers out in front of their peers.

Lies says in Canada, as in the United States, businesses can face tough monetary penalties if they cannot prove their employees received proper safety training in a manner that they could easily understand. In the United States, he says, there might also be criminal liabilities if someone “willfully violates” a regulation that then leads to the death of an employee. These penalties can be a big deal, but the bigger deal is employee safety, he points out. That is “the moral part, the human factor,” he says. “Let’s pretend OSHA never existed. Wouldn’t you still have an obligation to tell employees about hazards and help them avoid them if their lives are at risk?”

Bridging the Silence

Some recyclers have learned the hard way that language barriers might prevent even thoroughly trained employees from asking important questions that keep them and their fellow workers safe.

Ryan Glant, general manager of Pacific Iron & Metal Co. (Seattle), recommends encouraging workers to ask questions or ask to clarify details that can get lost in translation or conversation. “The biggest challenge is that employees who are not comfortable with English will often be too embarrassed or shy” to speak when they don’t understand, he says. “For a long time, we assumed that silence means understanding, but we are trying to do a better job of getting affirmative acknowledgement from our employees that they truly understand our communications,” he says.


Deiro agrees, adding that there are many reasons an employee might not understand a safety communication, whether or not there is a language barrier: The scrapyard is loud, for example, and employees are learning about subject matter that is complex and detailed. Regardless of the reason, supervisors have an obligation to make sure the lines of communication stay open, she says. Workers “need to have the knowledge that it’s OK to say, ‘I didn’t understand that.’” At SA Recycling, that message starts at the top, she says: CEO George Adams made the phrase “speak up” part of the employee culture. How do supervisors know their employees understand what is going on in the yard and are getting their questions answered? Encourage them to speak up, she says, either through an interpreter, through written communication, or another avenue. “Listen more, and talk less,” she says. “Listen to your employees [because] you need to have their involvement.”

In other words, don’t just ask your employees if they “get it” and walk away, Lotzkar says. “The common-sense approach is to be patient,” he says. “We want them to have every opportunity [to] propel our company forward in a safe and effective manner.”

Bilingual Heroes

In many scrapyards, bilingual employees are communication MVPs: Their ability to talk fluidly with people who speak different languages makes them ideal interpreters during work meetings and site visits, and they often can translate training documents or PowerPoint presentations. They even become critically important to emergency medical personnel in the event of an injury or accident in the scrap­yard that involves people who cannot describe their injuries in English.

Andy Wichman, environmental health and safety manager for Schupan & Sons (Kalamazoo, Mich.), says that in the past, the company’s Spanish-speaking employees watched training videos in Spanish, but the primarily English-speaking trainers had trouble getting feedback from the group when training was done. That changed when Schupan & Sons realized its retail manager, Uriel Arechiga, is bilingual and has a good rapport with the company’s other Spanish-speaking employees. The company asked him for help interpreting workers’ questions and comments during safety meetings, and it also asked him to translate the safety training PowerPoint slides into Spanish. Arechiga says he noticed the difference right away. Once the company started actively seeking out his interpreting skills, the Spanish-speaking employees went from being the quietest “to being the most outspoken,” he says. “Out on the floor, they always say, ‘I have questions.’”


Wichman says Arechiga’s interpreting skills have made a huge difference in the way the company communicates with employees. It’s not just that Arechiga knows two languages, he says. It’s that he is a member of the team who has built relationships with his fellow workers and can accurately relay information that might otherwise fail to reach those who need it. “They already know him and trust him,” he says. “The Hispanic population [of the company] has a better voice now when it comes to safety things.”

Arechiga recommends that other scrapyards talk with their bilingual employees to see if they are interested in serving as interpreters, thus helping employees who feel they have no voice. “If there’s anyone who can help translate, start getting them involved in safety meetings and trainings. It’s [hard sometimes for non-English speakers] when you’re having trouble getting your point across and you don’t have the right words.”


Schupan values the work that Arechiga and other bilingual employees do to keep the lines of communication open, Wichman says, yet companies cannot always expect bilingual employees to spend time interpreting day-to-day interactions while also doing the job they were originally hired to do. The company hires an outside firm to provide interpreters for some personnel matters, especially ones related to hiring, he says. “Our HR department has just contracted with a service that will be providing a bilingual person to assist in new employee orientations and [providing] benefit information.”

An interpreter might not be necessary for every communication, Glant says, but Pacific Iron & Metal makes sure to have interpreters when discussing more complex subjects. “In general, our communications are made in English with a translator for a few of our Spanish speakers. We recently had a 401(k) [retirement plan] education session offered in Spanish and in English because of the complexity of the subject matter,” he says. In another instance, one bilingual employee recently became a certified forklift trainer “so that he can offer forklift training to Spanish speakers that are on staff or that we may hire,” he says.

A Shortage of Resources

Take a stroll through scrapyards in different regions of North America, and you will see signage that reflects not just workers’ languages, but also the language resources available in the region. In some yards, safety signage is only in English, even if many employees speak Spanish as their first language. In other yards, the signs are in many languages. OSHA does not require multilingual safety signs or training materials, so how do scrapyards decide what materials to translate? Recyclers say they would like to make those decisions solely based on the needs of their employees, but many find it hard to get their hands on the right language resources to get the job done.

SA Recycling is working toward translating all training materials into Spanish, Deiro says, but it has only a few employees with the language skills to make it happen. Translators tackle training and safety-related materials first, then go on to translate items such as employee bulletins. The translations are time-consuming, however, and they don’t always turn out perfectly, she says. For example, the company once ordered notebooks with safety tips printed on the front cover. The Spanish-language version was written in a formal style—the kind some English-speaking students learn in Spanish class—and it took several months before a native Spanish speaker pointed out that the wording was not typically used in everyday conversation and was confusing.


SA hopes to have more translation resources in the future, but Deiro wishes the company also had more outreach. “Part of the confusion [comes from] different dialects—there’s people from El Salvador, from Mexico, people who speak what they call Spanglish, people who speak their own slang in the yard,” she says.

Pacific Iron & Metal used a professional service to translate its employee handbook into Spanish, but for smaller internal policy documents and notifications, Glant says, the business often relies on a combination of Google Translate and a bilingual employee to get the wording right. There are even fewer safety resources available for their employees from Laos and Cambodia. Every once in a while, Glant will see safety bulletins in those languages and pass them along, “though in general, [those employees’] proficiency with English is adequate for most communications,” he says.

Lopez Scrap Metal in El Paso, Texas, is just minutes from the border between the United States and Mexico. About 99 percent of the company’s 61 full-time and 10 part-time employees speak Spanish as their first language, and about 65 percent are bilingual in Spanish and English, according to Luis Carlos Loya, director of purchasing and the company’s safety officer. Day-to-day operations in the yard take place in Spanish, but you’ll find few Spanish-language safety signs.

Loya says even in a town where so many speak Spanish, it can be tough to find Spanish-language signage or training resources if you don’t know where to look. Yet his employees don’t always need everything to be in two languages, he points out. Instead, the company uses commonly recognized symbols. For example, you won’t see a sign stating “No Fumar” at Lopez Scrap—employees know what to do when they see a sign depicting a cigarette with a red line through it, he says.


At Pacific Metals, Lotzkar says most signage is in English or uses pictograms that are easy to understand. More-complex safety signs for emergency shutdown procedures, however, are posted in multiple languages, including Burmese.

Available Tools

When hunting for needed communication tools, many recyclers look for resources in their own yards first, such as a bilingual employee who can act as an interpreter. Yet recyclers say they have found great resources outside their doors, too.

Loya says Lopez Scrap has found essential training videos, documents, and other Spanish-language resources from the Occupational Safety and Health Consultation program, or OSHCON, a free, OSHA-funded service available to private employers through the states, in this case through the Texas Department of Insurance Division of Workers Compensation (visit www.osha.gov/dcsp/smallbusiness/consult.html for options in your area). OSHCON helps employers understand and comply with OSHA health and safety requirements. Lopez Scrap uses Spanish-language training documents OSHCON provides, and Loya says he often borrows Spanish-language safety videos free from OSHCON’s library. “OSHCON was a blessing for us,” he says. “Having access doesn’t cost us a penny, and they even mail materials to us [free] as long as we return them in seven days.”


In Vancouver, Lotzkar says Pacific Metals works with the Immigrant Services Society of British Columbia, which helps translate résumés and job-related materials into other languages. The Vancouver-area organization’s goal is to find jobs for recent immigrants, and it offers the translation services as a way to connect the scrapyard to new employees and the immigrants to new jobs, he says.

For its Spanish-speaking employees, Pacific Metals also uses ISRI’s Spanish-language safety videos, Lotzkar says. Some equipment companies also have created training videos for specific models of equipment in languages other than English, including Spanish and French.

OSHA also offers multilingual resources online and in person. One option is to call a diverse workforce/limited English proficiency coordinator, who can offer advice and resources for outreach, education, and training to workers who speak a language other than English.


Despite the challenges of ensuring workers with limited English proficiency get adequate safety training, many employers say such employees also are a great asset in an industry that is becoming increasingly global. In Vancouver, Lotzkar says he expects his scrapyard to become even more diverse as time goes on, while Wichman and Deiro say their Spanish-speaking employees will always be part of the fabric of their operations. The message for all recycling businesses should be the same, regardless of language, Deiro says. “The bottom line is, we’re doing everything we can to provide a safe workplace for employees … . Employees deserve to go home to their families every night without injury.”

Megan Quinn is reporter/writer for Scrap.

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