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SSTA Policy

 Southwest Safety Training Alliance, Inc.

Business Conduct

 

Operating Policy #1

Purpose:

One of Southwest Safety Training Alliance Inc. (SSTA) greatest assets is our reputation as an ethical business committed to our customers and instructors and the values outlined in our Mission Statement. This reputation has been built upon a policy of compliance with all laws and the conduct of business corresponding with the highest standards of moral and ethical behavior.

Scope:

The SSTA  is committed to comply with the laws and regulations that address our business conduct. To ensure continued compliance; SSTA has prepared a detailed Business Conduct Operating Policy, to provide further guidance to all instructors and members on acceptable business conduct.

Our goal is to continue to be recognized as a company of the highest integrity and highest ethical standards of conduct. Each and every one of us must follow a course of business conduct in accordance with these Policies to preserve our reputation for legal, moral and ethical behavior.

Objectives:

  1. To establish or communicate basic principles that assist SSTA instructors in making Business Conduct decisions.
  1. To provide guidance to SSTA instructors on acceptable business conduct to ensure consistency in professional and ethical responses to our customer needs,
  1. To standardize the training and documentation required to substantiate Business Conduct.

Implementation:

 Each member company and person must put into place the necessary procedures to implement this policy.

Operating Policy #2

 Purpose:

 Define the objectives and functions, of the SSTA Business Practices. This policy covers all on-going activities of the SSTA Business Practices.

 Scope:

 Ensure that the Business Conduct Operating Policies are implemented and maintained effectively.  These policies shall reference, and be in agreement with, the SSTA Bylaws as adopted in August 1997 and updated in 2009.

 Objectives:

  • Periodically evaluate the effectiveness of these Business Conduct Operating Policies and determine whether amendments are required.
  •  Identify significant changes in the external environment (including changes in technology, laws, training options), market place, and internal operations and determine what, if any, changes to the Business Conduct Operating Policies are necessary.
  •  Review and approve certain actions, agreements, etc. as stipulated in the Business Conduct Operating Policies.
  •  Review internal audit reports on activity relevant to the Business Conduct Operating Policies and take appropriate action.
  •  Document actions taken in carrying out responsibilities.

Operating Policy #3

 Purpose:

 It is the intentions of the SSTA that all material, training aids, etc., that are the property of the SSTA, will be distributed through the SSTA Executive Director’s office or appointed committee.

 Scope:

 To ensure that training materials, training aids, etc., will be managed by the SSTA Executive Director.

Objectives:

 

The Executive Director shall ensure that:

  • There is no distribution, of any material, to unauthorized or uncertified persons.
  •  All material shall be sold for the exact cost deemed appropriate by the SSTA Board of
  • Directors.
  •  Instructional materials shall be offered equally to all instructors prior to being sold to one individual or company.  This action ensures availability of materials as needed for SSTA business activities.
  •  Materials that are owned or used by designated persons for the SSTA shall remain
  • the property of the designated person(s).

Operating Policy #4

 Purpose:

Define the policy and procedures to be followed to add or amend the SSTA Operating Policies.

Scope:

 Any individual may propose a new policy or policy revision. In order to do so, the individual must bring in person, fax or e-mail a written proposal of the requested policy change to the SSTA headquarters.  The SSTA Board of Directors will review this proposal and place before the membership as outlined in the Corporate Bylaws.

Objectives:

  1. Proposed additions and amendments must be presented to the SSTA Board of Directors for review and input.
  1. The SSTA Board of Directors must approve policy changes, additions, or deletions by a majority vote and the President and Secretary of the Board shall sign those amendments as a final action document.

All correspondence and inquires relating to the SSTA Operating Policies should be addressed to:

Executive Director
Southwest Safety Training Alliance
125 South 52nd Street  
Tempe, AZ 85281

 

Operating Policy #5

Purpose:

To establish the procedures for SSTA to have an audit function.

Scope:

 The audit function exists to serve the interests of industry, regulatory requirements, and to apprise the executive director and SSTA Board of Directors concerning the adequacy and effectiveness of the systems and the integrity of the SSTA, and its programs.

Objectives:

 The audit function includes

  • Appointment of an audit team consisting of at least three members
  • The audit team will develop a yearly audit plan and submit the plan to the executive   director and SSTA Board of Directors for review and approval.
  • Publish the approved audit plan for all instructors and member companies.
  • The audit program shall be documented and reference the appropriate SSTA policies.
  • Update and adjust the audit program as necessary.
  • The audit team shall conduct an annual comprehensive review of the audit program and procedures to ensure compliance with current industrial and regulatory policies.
  • All significant changes to the audit program and procedures are to be reviewed and approved by the SSTA Board of Directors.
  • The audit team shall audit training materials; instructor course delivery and records management in accordance with the audit plan and make recommendations to the executive director and SSTA Board of Directors concerning all matters relating to compliance with established SSTA Business Conduct Operating Policies.


Operating Policy #6

 Purpose:

To ensure the SSTA maintains ethical and legal compliance in accordance with the established Business Conduct Operating Policies.

Scope:

 To appoint a Compliance Committee to address ethical and legal compliance issues. The committee shall have overall responsibility to establish compliance standards and procedures and oversee compliance with the SSTA Operating Policies and Procedures as its foundation.

Objectives:

 The Compliance Committee duties and responsibilities include the following:

  • Review and establish SSTA Operating Policies and Procedures in order to ensure that the SSTA has in place effective programs to detect and prevent ethical and legal violations.
  • Ensure that the SSTA policies and procedures are communicated effectively to SSTA member companies, instructors, and staff, through trainer orientation programs, publications and other appropriate means.
  • Ensure that reasonable steps are taken to achieve compliance with the policies and procedures throughout the organization by using appropriate monitoring, auditing and reporting mechanisms.
  • Notify the executive director of any possible policy and procedure violations and if initiate and direct investigations of possible violations.
  • Direct enforcement of SSTA policies and procedures through appropriate measures, including discipline of member companies, instructors, and staff for violations and, if warranted, Disciplinary action shall be set forth by the SSTA in accordance with SSTA Operating Policy #12.

Operating Policy #7

 Purpose:

 To ensure that SSTA fully complies with all requirements in all areas in which it conducts business:

Scope:

SSTA will comply with established regulatory requirements, including marketing approvals, new technology, and new materials or other regulations/controls by government agencies.

Objectives:

  1. SSTA shall ensure that materials meet minimum regulatory requirements.
  1. SSTA shall conduct audits of the material and class presentations on an annual basis. (Refer to Operating Policy #5.)

Operating Policy #8

 Purpose:

The regulatory Compliance Policy is intended to explain and assist the in developing or revising compliance procedures.

Scope:

 To ensure that SSTA complies with the regulatory requirements, including marketing approvals, new technology, and new materials or other regulations/controls by government agencies.

Objectives:

 

  • Regulatory Audits

An annual regulations audit schedule should be developed and published.  The SSTA Audit Plan shall be the basis for audits each year in accordance with SSTA Operating Policy #5.

  • Communication

“SSTA Compliance Update” should be used to communicate with the members of SSTA by the executive director and the SSTA Board of Directors.


Operating Policy #9

 Purpose:

 It is the intention of SSTA to provide an awareness of SSTA’s position on alcohol and drugs.  SSTA takes a strong stand on this issue to protect the safety and health of SSTA members, instructors, staff, visitors or customers.

Scope:

 The policy of SSTA is that the use or possession of illegal drugs or being under the influence of alcohol is strictly prohibited when conducting SSTA business, providing classroom instruction, or while participating in SSTA training classes, meetings, or programs.

Objectives:

 The ensure compliance with this policy on the use of alcohol and/or illegal drugs, the following rules shall be observed:

Definitions:

  • “Illegal drugs” are drugs or controlled substances which are (1) not legally obtainable or (2) legally obtainable but not obtained or used in a lawful manner (3) mind-altering and/or (4) addictive substances which are not sold as drugs or medicines but are used for mind or behavior-altering effect.
  • “Under the Influence” is defined as any substance which impairs ones ability to do ones job, or prohibits others from learning in a classroom environment due to disruptive behavior.
  1. Possessing, using, buying or selling of illegal drugs anytime while dealing with customers shall mean immediate termination, disqualification and/or removal from SSTA.
  1. If off-duty use of alcohol or drugs causes job behavior or performance to suffer, disciplinary measures will be taken in accordance with SSTA Operating Policy #12.  In severe cases this can mean disqualification from SSTA.


Operating Policy #10

Purpose:

 To define conditions for organizing and providing support for customers and instructors, which are members of the SSTA and have a relationship to the SSTA business, and provide further guidance and direction in complying with policies on Business Conduct?

Scope:

 The SSTA will fulfill its affirmative duty and responsibility to make available to its instructors the instruction, education, and training necessary to explain the effective use of its products.

Objectives:

  1. Program Selection – All programs must be based on industrial information, regulatory issues, need, usefulness, and technical merit.
  1. Membership and Instructor Fees – Shall be set by the SSTA Board of Directors and reviewed annually in accordance with the SSTA Bylaws.
  1. Documentation – Each program shall have adequate documentation indicating the educational content, activities, participants and authorization.
  1. Review – Training curriculums and instructors shall be subject to an annual audit by the Audit Team in accordance with SSTA Operating Policy #5.
  1. Administrative Fees – Should be reviewed annually by the executive director who shall make recommendation to the SSTA board of directors.  Fees may be adjusted based on organization need.

Operating Policy #11

 Purpose:

 To define appropriate services which professional Instructors shall render.   SSTA will provide instructors with guidance and direction in complying with the following provisions of the Policy on Business Conduct.

Scope:

 SSTA Instructors shall fulfill their duty and responsibility to make available, to the trainee, useful and real value information concerning industry and will explain the effective use of its products and necessary skills to perform a task.

Objectives:

  1. Agreement to teach SSTA curriculums may be entered into only for those a service for which there is a legitimate need. The SSTA shall not be involved in agreements between instructor and trainee.
  1. SSTA approved Instructors shall meet and maintain training standards of the SSTA.
  1. SSTA Instructors shall not present themselves as authorized agents of SSTA without prior written approval of the SSTA Board of Directors.
  1. Instructors shall ensure that material is presented correctly and follows regulatory compliance requirements at all times.
  1. Documentation – Files on all agreements and training must include all critical information; e.g., instructor’s qualifications and credentials, required performance, procedural formalities and other unique specific provisions.  Such information shall be delivered to the SSTA for document control and retention.
  1. Current curriculum shall be reviewed annually, or as required by the SSTA for compliance, by the Compliance Committee and audit team in accordance with SSTA Operating Policies #5 and #6.
  1. Each instructor shall utilize the approved safety training or Cleanroom protocol material for SSTA classes.  Supplemental materials may be appropriate to satisfy procedures, and requirements for the specified course.
  1. All instructors shall assess that trainees demonstrate and understand through written tests, the competencies required before authorizing issuance of SSTA cards, to the trainee. If the trainee does not pass the core test (80% or better), the trainee may retake the course at a later date.

 

Operating Policy #12
  1. Instructors must conduct themselves in a professional manner at all times. All instructors shall refrain from acts of bias or prejudice and remain impartial at all times.
  2.  Instructors are considered worthy of high regard, as are trainees. Respect will be shown at all times when dealing with trainees. If trainee is disrespectful and uncontrollable, the instructor is empowered to dismiss the trainee from the class.  This removal shall be communicated to both the SSTA office and the individual’s company by the next business day.
  3.  Integrity – Decisions affecting trainees must be based in firm adherence to a code of ethical values.

Operating Policy #13

 Purpose:

 It is the intention of SSTA to provide an equitable process for the Executive Director/Audit Team in helping instructors correct any deficiency in their performance and/or compliance with the SSTA Business Conduct Policies.

Scope:

 When an instructor’s performance has been evaluated as unsatisfactory or that he/she is not complying with the adopted SSTA policy, all reasonable efforts should be made to assist the Instructor in reaching or returning to an acceptable level.

Objectives:

  • Assess the workplace systems and environment to ensure that these areas are not the cause of the problem.
  • Discuss the situation/problem with instructor.
  • Attempt to reach a joint resolution, if possible. Copies of documented deficiencies and a written corrective action plan must be given to the instructor prior to initiating the corrective action process.
  • If the performance issue is potentially serious enough for disqualification, document and date all significant events as they occur.

Corrective Action Steps:

Initial Meeting.  The Instructor must be informed in writing of missed objectives, standards, or expectations. This meeting should be viewed as a problem-solving session rather than a punitive confrontation.

Corrective Action Plan.   A written corrective action plan should be developed which reinforces the intention of performance improvement.

Disqualification.   If performance does not improve to a satisfactory level as outlined in the corrective action plan, a written notice will be given by the executive director.  A (30)-thirty day appeal process is available to the instructor who may request a hearing by the SSTA Board of Directors.

 The SSTA Business Conduct Policies #1 through #12, “Guidelines for Certificate of Approval” for OSHA 29CFR1926 & 29CFR1910 and Cleanroom Protocol, Instructor Contractual Agreement, and the SSTA Instructor Application have been reviewed as revised and are hereby approved by the SSTA Board of Directors.

 Instructor Contractual Agreement

The Business Conduct and Policies provide guidance essential to the operations of the Southwest Safety Training Alliance inc. (SSTA). They reflect our shared values and our collective commitment to the SSTA’s mission and standards. These policies are intended to inform all SSTA individuals of their obligations to SSTA and our customers. They also clarify expectations regarding operational responsibilities.

The SSTA considers the content of these policies to be essential to meeting our goals. Our reputation for quality and high standards can be maintained only by honest and ethical dealings. All individuals associated with the SSTA must adhere to these policies without exception, as condition for remaining in good standing with the SSTA. The SSTA Board of Directors, executive director, instructors and employees are responsible for ensuring compliance with the policies.

SSTA is free to adopt any necessary additional procedures as long as they are consistent with the essential SSTA policies.