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Dain Co., Ltd.
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How do you verify previous training completion records when the supervisor changes?
2026.09.29 11:04
Hello, I am in charge of safety and health at a manufacturing company.
With the recent organizational restructuring, several on-site supervisors have been changed.
I am writing to inquire because it is unclear how to handle training for an employee who previously worked as a regular worker but has been newly designated as a supervisor.
As an existing employee, I have been continuously receiving regular safety and health training. If I become a supervisor, will the previously received training be recognized to some extent, or do I need to take supervisor training anew starting from the time of designation?
I would also like to know if my existing completion history can be recognized as is in the case where I have already worked as a supervisor in another department and have simply transferred departments.
Since organizational restructuring happens frequently, I am planning to establish a standard for verifying training history whenever changes occur.
Typically, based on the date the supervisor is appointed, what materials do you verify and manage?
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- 01coach AnswerHello, this is Nudge EAP โบ๏ธ. Since the health interview and the department head interview determine different matters before returning to work, we recommend conducting both. The health interview determines "which duties should be restricted based on the current health condition," while the department head interview determines "how to assign duties within those restrictions," so the health interview should come first. - Before the interview: Obtain job requirements from the department head, such as shift scheduling, weight limits for heavy loads, and equipment operation status, and pass them on to the employee. Instruct them to show these requirements to their attending physician during medical appointments. This makes it easier to obtain a more specific medical opinion rather than just a single line stating "able to work." - Health interview: Compare the medical opinion with the job requirements and finalize your opinion regarding a return as is, a conditional return, or a re-evaluation. If you find it difficult to make a judgment, you can request a work suitability assessment from an occupational health physician or an occupational and environmental medicine specialist. - Department head interview: Determine the placement and the plan for the first week of return based solely on the work restriction items from the health interview results. If you are concerned about the burden on the employee, you may conduct the meetings on consecutive days, or if the employee agrees, proceed with a single three-party meeting including the Health Manager. Even in this case, you should handle health matters only during the health interview session, and separate the discussion so that only work adjustments are discussed once the Department Head enters. It is safer to convey only the restriction items, duration, and review date to the Department Head, such as "Exclusion from night shifts for 4 weeks, exclusion from handling items over 20kg alone, review after 2 weeks," instead of the diagnosis or symptoms. Since health information is sensitive data and requires separate consent for processing (Article 23 of the Personal Information Protection Act), I recommend keeping the original medical opinion and health interview records separate from personnel records and sharing only the agreed-upon details of the work adjustment with HR and the Department Head. For reference, while the reinstatement procedure for general sick leave is not separately defined by law and follows the company's internal rules, if the illness was one that prohibited work (Article 220 of the Enforcement Rules of the Occupational Safety and Health Act), it is mandatory to obtain the opinion of a physician, such as a Health Manager or Occupational Health Doctor, before allowing the employee to return to work; therefore, it is advisable to verify this aspect first. I have organized an Excel role chart in the post below that generates a step-by-step schedule simply by entering the 6 pre-return steps, the scope of information sharing, and the expected return date. https://nudgeeap.com/community/risk-assessment/137145056 https://nudgeeap.com/community/risk-assessment/137148531112226.10.20
- 02CommentsWe also have a lot of short-term contract workers during peak season, so I get confused every time I have to handle the training for rehired employees. I'm also curious how other places handle cases where contracts are renewed immediately without any gaps.132226.10.21
- 03coach AnswerHello, this is Nudge EAP โบ๏ธ Article 4, Subparagraph 4 of the Enforcement Decree of the Serious Accidents Punishment Act stipulates that management responsible for safety and health must formulate a budget necessary to implement โ the provision of safety and health personnel, facilities, and equipment required for accident prevention, โก the improvement of hazardous and dangerous factors, and โข other matters notified, and execute it according to its intended purpose. Since improvement costs identified through risk assessments fall under the category of "improvement of hazardous and dangerous factors," it is correct that they should be reflected in the budget; however, the law does not specify which departmental budget account they should be allocated to. In fact, Subparagraph 5 of the same article grants safety and health managers and supervisors the authority and budget necessary for their duties, so formulating them into a departmental budget is also permissible. The key point is that you must be able to verify that the funds needed for improvements have actually been allocated and executed according to plan. Article 36 of the Occupational Safety and Health Act also mandates the establishment and implementation of improvement measures based on the results of risk assessments. Therefore, it is advisable to manage the reasons and schedules separately for items that have been stalled for several months under the "scheduled for improvement" status. In practice, it is common to operate them mixed together as shown below. - Facility improvements (workbenches, racks, local exhaust ventilation, etc.): Allocate a separate 'Safety and Health Improvement' item within the relevant department's budget. During the budget planning period, the Safety and Health department should submit a list of improvement measures and estimated costs to verify their inclusion. - Common/minor improvements or new items arising during the year: The Safety and Health department should establish a consolidated reserve item and execute them first in order of risk level. - Implementation management: Record the risk level, responsible department, budget source, expected completion date, and reason for non-implementation for each item in a ledger, and report to the head of management during the semi-annual inspection. Regarding the issue of "no budget this year, so we'll do it next year," establishing a standard where high-risk items are processed first in the current year as reserve items, while the remainder is recorded as a basis for inclusion in the following year's budget, will reduce disputes between departments. While improvements are delayed due to budget constraints, I recommend recording temporary measures such as changes in work methods or protective equipment. The format for the Improvement Measure Implementation Management Ledger and the items for recording management inspection meetings are summarized in the post below. https://nudgeeap.com/community/risk-assessment/134758888 https://nudgeeap.com/community/serious-accidents-act/134369648131126.10.15
- 01coach AnswerHello, this is Nudge EAP. As you mentioned, it is more important to verify โhow quickly a counselor matching the employeeโs desired criteria is connectedโ rather than the total number of counselors. Please request and compare the following items in your proposal using the same criteria: 1. Time taken from application to the first contact/initial consultation over the past year, and the assignment rate within 3/7 days. 2. Methods for reflecting gender, consultation topic, region, available time, and preference for in-person/non-face-to-face interactions in the matching process. 3. The actual number of available counselors by region, time slot, and topic, as well as availability for nights and weekends. 4. Counselor change procedures, additional costs, limits on the number of changes, and the time required for reassignment after a change. 5. Methods for providing alternative guidance and presenting options to employees when no suitable counselor is available. 6. Operational results and improvement examples, such as assignment satisfaction, counselor change rates, and dropout rates. In particular, rather than just looking at the number of registered counselors, such as a โcounselor pool of 1,000,โ the difference becomes much clearer if you request the number of currently active counselors, the number of recent actual assignments, and the average waiting time by region. If possible, it is helpful to provide the vendor with 2-3 identical virtual cases to receive an explanation of the allocation process and estimated time, or to receive a direct demonstration of the application screen and change procedures before signing the contract to compare them.618826.09.22
- 02coach AnswerHello, this is Nudge EAP.โบ๏ธ The simplest method is for employees to simply receive guidance and apply directly, as the company does not transfer personal information. If you want a health manager to forward a name and contact information to an EAP agency for contact, it is safer to explain the receiving agency, purpose, items, retention period, and the right to refuse consent, and to obtain clear consent from the individual. Since checkup results and symptoms are sensitive health information, do not consider them included in the existing health checkup consent; instead, please write down only the content to be conveyed and obtain separate consent. In practice, it is common to separate the options into โ consent for forwarding name and contact information and โก consent for forwarding checkup results and symptoms, ensuring that there is no disadvantage in using the EAP even if the second option is not agreed to. The burden of repeating explanations can be reduced by providing the option for employees to send a summary of their consultation request, written directly by the employee, to the agency. However, since the wording and procedures may vary depending on whether the contract with the EAP agency involves the outsourcing of personal information processing or the provision of information to a third party, please review the contract details with your in-house personal information manager before implementation. It is a good idea to define the scope of responses in advance to the company to prevent unnecessary feedback regarding consultation requests or their content.678926.09.21
- 03coach AnswerHello, this is Nudge EAPโบ๏ธ While it is difficult to definitively conclude that a non-face-to-face interview itself constitutes a procedural issue, please review your company's regulations and investigation guidelines first. Before a video interview, it is advisable to verify identity, confirm that the space is private, check for the presence of a third party, and confirm consent regarding audio or video recording. Additionally, it is recommended to record the content of the interview and obtain confirmation from the individual. If it is difficult to obtain a sufficient statement due to time differences or communication conditions, please inform the individual of the opportunity for supplementary written statements after the initial non-face-to-face interview or for an additional interview upon their return. Whether to conclude the matter solely through a non-face-to-face interview should be determined based on whether the subject's right to make a statement has been fully guaranteed, whether the facts are clear, and whether further verification is required. However, if the matter is ambiguous, it is safer to review the procedures with the labor and legal representative.656626.09.22
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