Many organizations are moving towards online training as the main method of educating their people in safety expectations. There are several reasons for this technology shift. Online training allows for greater flexibility in terms of scheduling, improved consistency of the content and it can be much more cost-effective when dealing in economies of scale.
Operationally, online training makes a lot of sense for many organizations. However, in moving towards online education, organizations should keep in mind two basic “proof problems” arising from online safety training, both of which can affect the strength of the due diligence defence of the employer.
The first problem involves identity verification, namely, how does the organization prove the person taking the training is the same person registered for the training? The second involves proctoring, that is, how does the organization prove the person taking the training was paying attention and not cheating?
The TV series Suits illustrates the identity verification problem. The main character in Suits, Mike Ross, is a brilliant young man with a photographic memory and an “off-the-charts” aptitude for taking tests. As a student, he gets caught cheating on a math test, loses his scholarship and finds himself on the streets of New York City, working as a bicycle messenger and supplementing his income by writing the Law School Admission Test (LSAT) for other aspiring students who struggle with the test.
In Suits, Ross disguises himself for the LSAT and provides fake identification. He enters the examination room pretending to be someone else and writes the exam for that person. He clearly would go to jail if caught. While the show does not involve online training, it demonstrates a universal problem for any kind of training where knowledge must be demonstrated: Protecting against people who will cheat the system for their own advantage.
The Alberta case of R. v. Rose’s Well Services Ltd. provides an example of both the identify verification and proctoring problems. In this case, the employer was convicted of occupational health and safety offences after two workers were badly burned in a fire while off-loading hydrocarbons from a tanker truck. The workers were filling a metal storage tank from their tanker truck when fumes from the process were ignited by the engine. The driver had parked the tanker truck too close to the metal storage tank and the engine provided the ignition source for the fumes that had gathered.
The employer, as part of its due diligence defence, called evidence that its employees had taken the Petroleum Safety Training (PST) course offered by Enform. This was an online training program that provided basic safety training for workers in the oil and gas industry and while not directly on point in terms of the fire in question, it was a component of the health and safety management system used by the employer.
In that case, the driver of the tanker truck testified he had helped his co-workers through the online training program and had even answered the exam questions for many of them. Needless to say, this came as a surprise to the defendant employer that discovered this fact at trial. The employer had naively assumed the training it was paying for was being taken by the employees intended.
In effect, the driver and his co-workers circumvented the intent and purpose of the training and denied the employer any return on that safety investment. At the time, there was no identification method used to ensure the identity of the person taking the exam nor any proctoring system of the exam to stop such behaviour.
There are economical solutions to these “proof problems.” An example of an organization using technology to address these problems is the International Competency Assessment Board (I-CAB). It uses computer software that automatically verifies the identity of the person using face recognition technology and monitors the assessment using algorithms designed to identify cheating. It sounds much like science fiction but technology has advanced this far. The program automatically stops the assessment if certain thresholds are met. While no system is perfect, I-CAB demonstrates the proof problems are not insurmountable and can be done economically and for different types of organizations.
The incentives to cheat the system are significant, as safety performance becomes a competitive differentiator for employees and companies. Organizations providing online training should be aware of the proof problems involved. Organizations considering participating in such training should ask about the methods used to address these problems. It is a fair question given the high stakes involved, as the Rose’s Well Services case aptly demonstrates.
In addition, some organizations are already recognizing the scope of the problem and the challenges inherent in web-based training. For example, the Industrial Occupational Health and Safety Association of Alberta is developing a best practices guideline for online training programs, to be available this year.
Operationally, online training makes a lot of sense for many organizations. However, in moving towards online education, organizations should keep in mind two basic “proof problems” arising from online safety training, both of which can affect the strength of the due diligence defence of the employer.
The first problem involves identity verification, namely, how does the organization prove the person taking the training is the same person registered for the training? The second involves proctoring, that is, how does the organization prove the person taking the training was paying attention and not cheating?
The TV series Suits illustrates the identity verification problem. The main character in Suits, Mike Ross, is a brilliant young man with a photographic memory and an “off-the-charts” aptitude for taking tests. As a student, he gets caught cheating on a math test, loses his scholarship and finds himself on the streets of New York City, working as a bicycle messenger and supplementing his income by writing the Law School Admission Test (LSAT) for other aspiring students who struggle with the test.
In Suits, Ross disguises himself for the LSAT and provides fake identification. He enters the examination room pretending to be someone else and writes the exam for that person. He clearly would go to jail if caught. While the show does not involve online training, it demonstrates a universal problem for any kind of training where knowledge must be demonstrated: Protecting against people who will cheat the system for their own advantage.
The Alberta case of R. v. Rose’s Well Services Ltd. provides an example of both the identify verification and proctoring problems. In this case, the employer was convicted of occupational health and safety offences after two workers were badly burned in a fire while off-loading hydrocarbons from a tanker truck. The workers were filling a metal storage tank from their tanker truck when fumes from the process were ignited by the engine. The driver had parked the tanker truck too close to the metal storage tank and the engine provided the ignition source for the fumes that had gathered.
The employer, as part of its due diligence defence, called evidence that its employees had taken the Petroleum Safety Training (PST) course offered by Enform. This was an online training program that provided basic safety training for workers in the oil and gas industry and while not directly on point in terms of the fire in question, it was a component of the health and safety management system used by the employer.
In that case, the driver of the tanker truck testified he had helped his co-workers through the online training program and had even answered the exam questions for many of them. Needless to say, this came as a surprise to the defendant employer that discovered this fact at trial. The employer had naively assumed the training it was paying for was being taken by the employees intended.
In effect, the driver and his co-workers circumvented the intent and purpose of the training and denied the employer any return on that safety investment. At the time, there was no identification method used to ensure the identity of the person taking the exam nor any proctoring system of the exam to stop such behaviour.
There are economical solutions to these “proof problems.” An example of an organization using technology to address these problems is the International Competency Assessment Board (I-CAB). It uses computer software that automatically verifies the identity of the person using face recognition technology and monitors the assessment using algorithms designed to identify cheating. It sounds much like science fiction but technology has advanced this far. The program automatically stops the assessment if certain thresholds are met. While no system is perfect, I-CAB demonstrates the proof problems are not insurmountable and can be done economically and for different types of organizations.
The incentives to cheat the system are significant, as safety performance becomes a competitive differentiator for employees and companies. Organizations providing online training should be aware of the proof problems involved. Organizations considering participating in such training should ask about the methods used to address these problems. It is a fair question given the high stakes involved, as the Rose’s Well Services case aptly demonstrates.
In addition, some organizations are already recognizing the scope of the problem and the challenges inherent in web-based training. For example, the Industrial Occupational Health and Safety Association of Alberta is developing a best practices guideline for online training programs, to be available this year.
