Anyone in safety for more than two months (a number I just randomly made up) knows OSHA’s general duty clause. For those of you who have only been around for 59 days or so, here it is:

“Each employer shall furnish to each of his employees employment and a place of employment which are free from recognized hazards.”

As an aside, please excuse the “his.” The OSH Act was passed in 1970, and while I’m sure (pretty sure… well, kind of sure) that lawmakers recognized that women could be and were employers, the English language still considered it “proper” to use masculine nouns and pronouns when making a general statement. Rest assured, the law applies to all employers, not just the male ones.

One facet of the general duty clause that is sometimes overlooked is that in carrying out their duty to provide safe work places, employers have to provide hazard training to their employees, and the trainee has to be able to understand the training.

That means if the employee doesn’t speak the language you, the employer or safety trainer, speak but instead speaks another language, you are still required to make sure the training is understood. Completely understood, not just the kind of understanding conveyed by hand gestures and emphatic grunts.

So how do we go about this bilingual training?

First off, you cannot rely on Google translate and similar programs, or even AI. They are spiffy tools, and have gotten a lot better, but if they still aren’t great at casual and informal speech. Think about the language and understanding gap between two people of different generations. You can be using the same words but mean completely different things. It’s like that but worse.

(I have a feeling I will soon be proven wrong about AI translators, if I’m not wrong already. But I never claimed to know everything)

Now that you know what not to do, what’s the answer? Honestly, the best answer is to learn the language. Since that probably isn’t possible (if it is, you don’t need this article), then someone who actually is bilingual (fluently bilingual) should be involved in the training. Training materials should be in the target language. Visual aids – like pictograms – are awesome at conveying information and should be used whenever possible in all training. You can also try peer-mentoring programs, which is really a fancy way of saying a co-worker who speaks the language is helping in training and with translating.

Look, I’m not just saying rah rah bilingualism (although I do say that), I’m saying it is an ethical obligation, United States federal law, and just a basic human consideration to make sure, absolutely one-hundred-percent-no-fooling sure, that your employees understand the hazards of the job. And it is our job as safety people to make sure it happens.

There is no one-size-fits-all answer to this issue. But you better figure it out.

-Douglas Stephens