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AGENDA ITEM REPORT

Title: Report on Request to Amend Regulation 1052 - Injury Reporting, Revision Date and Training Site Address
REPORT PROFILE
MEETING DATE
10/24/2019
BUREAU SUBMITTING THIS REPORT
Training Delivery and Compliance Services Bureau
RESEARCHED BY (PRINT NAME)
Ralph E. Brown
REVIEWED BY (PRINT NAME)
REPORT DATE
09/06/2019
APPROVED BY
DATE APPROVED
PURPOSE
Decision Requested
FINANCIAL IMPACT
No

ISSUE:

Section 1.6.2 of the POST Guidelines for Student Safety in Certified Courses 2007 states, “Presenters are encouraged to collect appropriate statistics regarding injury trends or experiences and exchange this information with other presenters and POST.” While presenters are encouraged to exchange information regarding training related injuries, there is no requirement to report said injuries to POST. 

 

POST staff review course certification documents on a regular basis. One of these documents is the course ECO. Because it is not a requirement to include a revision date (the date the presenter reviewed and updated the course ECO), very few presenters include a revision date. When present, a revision date is usually found in the document footer, with the page number. With the fast-paced change in legislation, technology, and tactics, revising content for a presenter is a mission critical task.

Currently, Regulation 1052 Subsection (b)(5)(D) and subsection (f)(2)(E)(D) require that course safety policies include the “Name, location, and phone number of the nearest emergency medical facility for each training site.” However, there is no requirement for the inclusion of the address, phone number, or name of a contact person for the training sites themselves. Requiring presenters to include the address, phone number, and name of a contact person for each of the training sites listed in a safety policy would reinforce the importance of student safety, proper documentation, and timely injury reporting. It also allows POST staff to ensure the safety and viability of possible training sites for POST-approved training. 

BACKGROUND:

Section 1.6.2 of the POST Guidelines for Student Safety in Certified Courses 2007 states, “Presenters are encouraged to collect appropriate statistics regarding injury trends or experiences and exchange this information with other presenters and POST.” While presenters are encouraged to exchange information regarding training related injuries, there is no requirement to report said injuries to POST. The proposed revision is necessary to not only ensure training is at all times conducted in a manner designed to minimize the risk of injury, but also to ensure that POST will be properly informed when an injury requiring more than basic first aid had occurred during a POST certified course. This information also provides POST staff with all available information for evaluating injury reports and identifying possible related trends.

 

POST staff review course certification documents on a regular basis. One of these documents is the course ECO. Because it is not a requirement to include a revision date (the date the presenter reviewed and updated the course ECO), very few presenters include a revision date. When present, a revision date is usually found in the document footer, with the page number. 

 

A problem occurs when there are questions about the correctness or contemporary content in the ECO, and there is no visible evidence when the ECO has been updated by the presenter. The lack of revision information can be problematic in court and when responding to California Public Records Act (CPRA) requests. 

 

It is entirely possible that a presenter does update their ECO, however if it does not indicate a revision date then questions can and will arise. POST staff do recommend listing a revision date as a best practice. But, there is often hesitation or resistance because there is no “requirement” for the inclusion of a revision date.

Currently, Regulation 1052 Subsection (b)(5)(D) and subsection (f)(2)(E)(D) require that course safety policies include the “Name, location, and phone number of the nearest emergency medical facility for each training site.” However, there is no requirement for the inclusion of the address, phone number, or name of a contact person for the training sites themselves. Requiring presenters to include the address, phone number, and name of a contact person for each of the training sites listed in a safety policy would reinforce the importance of student safety, proper documentation, and timely injury reporting. Additionally, it allows POST staff to ensure the safety and viability of possible training sites for POST-approved training. This information also provides POST staff to identify possible discrepancies between locations listed in the course certification materials and in the course safety policy during the course certification process.

ANALYSIS:

Regulation 1052 - Requirements for Course Certification, lists the requirements to obtain course certification.

Subsection (a)(9)(D) indicates the requirement for inclusion of "formal written safety policy" for POST-certified courses involving manipulative skills training.

If approved by he Commission, POST staff would recommend the inclusion of the reminder for safe training practices and the requirement for training related injury reporting as Subsection (a)(9)(D)(1) and Subsection (a)(9)(D)(2) as:

"1. Training shall at all times be conducted in a manner designed to minimize any risk of injury and to promote student, staff, and instructor safety."

"2. The POST Regional Consultant shall be notified in writing within 5 business days when an injury requiring more than basic first aid occurs during training." 

If approved by the Commission, POST staff would recommend placement of the revision as (D) between (C) "Ratios of instructional staff to students" and (E) "Name, location, and phone number of nearest emergency medical facility for each training site."

Subsection (b) (3) lists the requirements of the course outline for Certification I, which shall minimally include:

  • presenter name, 
  • presenter identification number, 
  • course name or title on each page, 
  • page numbers, 
  • statement of purpose, and 
  • subject topics to the second level of detail to sufficiently indicate technical information in the subject areas.

There is a similar requirement for Certification II, which includes:

  • presenter name, 
  • presenter identification number, 
  • course name or title on each page, 
  • page numbers, 
  • statement of purpose, 
  • subject topics to the third level of detail or learning objectives and minimum topics to sufficiently indicate the technical information in the subject areas, 
  • student activities, and 
  • methods for assessing student learning.

POST staff is recommending the inclusion of a "revision date" in the course outline. Best practice for the location of a revision date is in the document footer, near the page number.

If approved by the Commission, POST staff would continue to recommend placement of the revision date in the document footer. 

Subsection (b) (5) (D) and subsection (f)(2)(E)(D) list the content requirements of course safety policies which minimally include:

  • Presenter Name/Presenter Identification Number
  • Course Name or Title
  • Page Number
    • Rules of safety and conduct
      • General rule
      • Course specifics
      • Site specific rules
    • Reporting and handling injuries
      • Minor injuries
      • Major injuries
    • Ratios of instructional staff to students
    • Name, location, and phone number of nearest emergency medical facility for each training site

    POST staff is recommending the inclusion of "Address, phone number, and contact person for each training site" in the course safety policy.

    If approved by the Commission, POST staff would recommend placement of the revision as (D) between (C) "Ratios of instructional staff to students" and (E) "Name, location, and phone number of nearest emergency medical facility for each training site."

RECOMMENDATION:
If the Commission concurs, the appropriate action would be a MOTION to approve the changes as described in the staff report; to add a reminder for safe training practices and a requirement to report training related injuries requiring more than basic first aid, a revision date in the footer of the course ECO document, and a requirement to include in course safety policies the address, phone number, and name of a contact person for each training site.
 
ATTACHMENT(S):
Name: Type:
1052.pdf Backup Material
1052_revision_date.pdf Backup Material
1052_revision_date_and_location.docx Backup Material
1052_Proposed_Amendment_Injury_Reporting_Revision_Date_Training_Site_Locations.docx Backup Material