As promised, in this issue we continue the topic of proper documentation of different types of briefings and the frequent mistakes in their conduct.
It is now the turn of the Periodic Briefing
The Periodic Briefing is intended to maintain and supplement workers' knowledge of occupational safety and health.
The Periodic Briefing shall be provided in accordance with a Programme approved in advance by the Employer, not less frequently than once every three months for workers directly engaged in high-risk activities, including:
- • in underground, mining and geological exploration sites;
- • in quarries;
- • in oil and gas extraction sites;
- • in the carriage of goods by rail;
- • in the production and use of explosives;
- • in the international carriage of goods by road;
- • in the carriage of dangerous goods by road;
- • in the handling of hazardous chemical substances and preparations;
- • in construction and assembly works.
Not less frequently than once a year for all other employees, according to a Programme approved in advance by the Employer, unless a lesser frequency is prescribed in other regulations.
The Periodic Briefing shall be documented in a workplace briefing book, periodic briefing, emergency briefing (this is the same book in which you have documented the workplace briefing).
The persons instructed shall recorded by serial number.
Important!! For activities requiring periodic briefing not less frequently than once every three months (quarterly) and for activities requiring periodic briefing not less frequently than once a year, the column ‘Signature of the Supervisor authorising the independent work’ shall be left blank, i.e., NOT completed.
General rules for proper documentation of the briefings.
The briefing books must comply with the Ordinance.
Columns and rows cannot be removed and/or omitted.
It is possible to order the briefing books in a printing house with data of the organization/enterprise, as well as with more pages or larger format, bigger line spacing, watermark or logo, etc., however, this is not common practice.
Serial number of the briefing (consecutive numbering).
The first column of each briefing book is (consecutive numbering). This is the number documented in the briefing book. When conducting initial briefing and onboarding for three people at the same time, these are three separately conducted briefings. Accordingly, each individual briefing of each employee should be recorded with its own serial number. In the next initial briefing, the consecutive numbering should be continued, i.e. without repetitions or interruptions.
All three names of the briefed person should be written in the columns.
In the sample of all three books in column 2 “First Name, Middle Name and Last Name of the Briefed Person” should be entered. This means that the set sample, according to the Ordinance, mandates spelling all three names of the briefed person and no abbreviations or writing down just the first and last name is allowed.
In the next two columns, the unit and the position of the person should be written down.
Two of the columns of the briefing books are entitled respectively:
"Workshop, unit, department, section"; "Position, type of work, profession"
Two of the columns of the briefing books are entitled respectively: "Workshop, unit, department, section"; "Position, type of work, profession"
It is important to write down fully the unit or position.
Abbreviations can be used, which unambiguously define "Workshop, unit, department, section" or "Position, type of work, profession". There is no explicit prohibition on their use, if they are common in the organization/enterprise.
The inspectors should check that the books have been filled in correctly and that the briefing actually took place, and not just as a formality. If the books are filled in incorrectly, they might be interpreted incorrectly later when they are needed.
The usage of the repeat sign is prohibited (-||-)
Using the repeat sign ( - || - ) is common practice when people need to write down 10 or more times the name of the same office or position.
There is no explicit prohibition in the regulatory framework, but the title of each column explicitly stipulates how the respective box should be filled in, regardless of the fact that the regulatory framework does not contain an explicit prohibition. The briefing books are important documents that protect you from a number of complications. It is important that the records look diligent and not kept just as a formality.
If the books are filled in incorrectly, they might be interpreted incorrectly later when they are needed.
A separate signature of each instructor should be affixed to each trainee.
Sometimes, when a group briefing is held, the instructor affixes several long signatures horizontally in the column, certifying the conduct of the briefing to a group of employees/workers.
Remember that the briefing of each employee is a separate act and it needs to be certified separately. Signing in the above-mentioned manner hints at formalism and is not conclusive evidence of conducting the briefing.
There should be no blank rows in the books.
Sometimes, for the sake of clarity, one or two rows may be skipped between two briefings or a new page can be started without finishing the previous one, in which case its rows remain blank. This creates conditions for more briefings to be added later.
Of course, you can start the next briefing on a new page and you can leave blank rows between two consecutive briefings, but they must be (closed), i.e. the blank rows should be marked with the commonly accepted for the purpose "Z" sign or in another way suitable to you, so that these cannot be used later.
The Ordinance does not explicitly describe whether or not you can leave blank rows or pages, but consistency, integrity and traceability of the records must be ensured and accidental or illegal destruction of information or its alteration by unauthorized persons must be prevented.
Mandatory signature of the trainee.
If there is no signature of the trainee, this practically means that no briefing has been conducted. The signature of the trainee is the written proof that he/she has been "briefed".
Mandatory signature of the instructor.
The lack of a signature of the instructor means that the legal requirement for documenting the briefing has not been met.
It also leads to the conclusion that there was something wrong with the briefing, i.e. the briefing book is left only for collecting signatures as no actual briefing has been conducted. The consistency of taking enough time to conduct a briefing but not finding sufficient time for the instructor/trainee to sign the book and certify the briefing causes doubt.
There is no legal requirement to whom should fill in the briefing books.
The only obligation is that the signatures should be affixed by the persons themselves.
The officials conducting the briefings are provided for with an order, and they must have been trained and have a valid certificate issued.
In a separate edition we will address the topic of briefings and briefing books in the conditions of remote work.
If you need assistance in filling out the briefing books, the team of HEALTH & SAFETY Occupational Health Service is at your disposal.