Page 7 - jan-feb2019
P. 7

LP gas board  | comments & reviews


            The following article first appeared in the June/July 2018 edition of the APGA magazine.  I have asked
            to reprint this article because we are still discovering permit holders that have not applied for Employ-
            ee Competency Cards for their “grandfathered” employees due to the belief that the new regulation
            does not apply to their particular situation.  In many cases, existing long-term employees are assumed
            to have completed all previous board requirements negating the need to obtain a card.  However,
            possession of a card is the only way to ensure that employees are truly “grandfathered” and to protect
            against liability exposure.

                       n April 3, 2017 the board implemented     intended to serve as educational tools qualifying
                       a new examination process for industry    one to perform a particular task   They are
                       employees known as Alabama                intended to serve as evaluations of the training
           OAdministrative Code 530-X-2- 11                      and experience an employee has received in an
            Employee Competency Requirements   On that           attempt to ensure a minimum level of knowledge
            date, existing employees within the state that       and skill is present in the interest of safety
            had completed all previous board requirements        Successful completion of the various examinations
            to work within the industry unsupervised were        is not the end of the educational experience
            not required to meet the new testing guidelines      for industry employees   Their employers should
            “Approved” existing employees were only required     remain vigilant in promoting continual training and
            to obtain an Employee Competency Card with           instruction
            a “grandfathered” status by simply providing              Some employers have expressed frustration
            evidence of having met the former testing            that the board does not provide the questions
            requirements   Applications to obtain cards for      and answers as study guides for the examinations
            “grandfathered” employees were requested to          Such information would only prove literacy of
            have been completed within one year by April 3,      examinees rather than a working understanding
            2018                                                 of the knowledge and skills desired   Instead, the
                 As we began to process cards for existing       board provides specific topics in a study guide for
            industry employees, some employers discovered        each of the examinations.  I agree it is difficult for
            that they had not met the previous board             a brand new employee to successfully pass these
            requirements for employees when first hired in the   examinations and evaluations without adequate
            past   Effective April 2017, these “unapproved”      training and experience in advance   Quite frankly,
            employees were required to complete the new          I can’t justify anything to the contrary   Common
            examination program regardless of the amount         questions are “Do you know how long it takes
            of time they had worked for the employer   Worse     to get a new employee trained?”  “What if it is
            still, some had been working unsupervised which      December when I hire a new employee with no
            created potential liability exposure for employers   prior experience?”  The amount of training and
            as this was in violation of board code   Some        experience will vary with each employee as we
            employers have yet to obtain a “grandfathered”       all learn in different ways and at different speeds,
            card for their employees, and they assume that       and the hiring of an inexperienced employee in
            they have letters in their files clearly demonstrating   December will be of limited use regardless of exam
            that they completed all the board’s previous         grades with the board
            employee examination requirements   If you have           The passing rate on first attempt with
            failed to apply with the board and obtain your       our exams is approximately 66%   While some
            employees’ competency cards, are you sure that       employees fail on the first try, we see them pass on
            your employees are legal to be performing their      their second or sometimes third attempt   The fact
            daily duties?                                        they eventually find success tells me that they have
                 I hope I have adequately addressed              increased in knowledge and exam preparation
            “grandfathered” employees and will now move          Failure is one of our greatest teachers if used as
            on to new hires required to complete the board’s     motivation to learn   Help your employees prepare
            examination requirements   First, I would like to    for the exams, and use the results as tools to focus
            express the purpose of the exams   The various       training.■
            examinations and practical evaluations are not


     7                                     Alabama Propane Gas Association  |  January / February 2019
   2   3   4   5   6   7   8   9   10   11   12