Anyone using Class 3B or Class 4 laser systems must receive some form of laser safety training. The key question for employers is whether to view training as a compliance metric or as a practical path to safety competency. There are many ways to provide training, ranging from traditional classroom settings to a range of online approaches. There may even come a time when laser safety training will be delivered through virtual reality goggles. The need for training is clear in any case. But no laser standard touches on the question of competency: Does an individual understand the material well enough to perform laser work in a consistently safe manner? The Z136.1 Safe Use of Lasers standard requires laser safety training and even suggests topics to be covered. But it neither requires nor mentions an examination. Fortunately, the inclusion of an examination is common in many live and online training programs. These exams often just test short-term memory. If the aim were to gauge a practical understanding of the material, then more thoughtful questions would be required. Requiring an exam after training or after individual modules is not as simple as it sounds, however, and it requires several decisions to be in place. Once a decision is made to make an exam mandatory, the next question is: What qualifies as a passing grade? Should it be 100%, 80%, or 51%? Another question is how to handle a failing grade. Online training courses usually direct students to immediately retake an exam if they do not pass. Will the subsequent exam repeat the same questions over again until the student gets enough answers correct to receive a passing grade? Or will a completely new test be presented? Repeating the same questions until the student gets them right is the least effective way of determining competency. Such exams often frame questions in a multiple-choice format. So, all a student needs to do is keep choosing different answers until the software grants a passing grade. There have even been cases where students skipped the course material and went straight to the quiz. If an exam is given after a live class, what should the instructor do if a student fails? One option is to send them the correct answers with an explanation of why the answers are right. This may be more expedient than prohibiting a student from performing any unsupervised laser work until they can repeat the class. The alternative would be for them to retake the exam. However, it often helps to sit down with students to go over the exam; language issues may be at the root of their incorrect answers. There is also the question of the wording or formatting of the questions themselves. Those who design, monitor, and grade exams need to know the audience. Clear language is critical to ensuring comprehension of a question, as well as the available answers. The aim is not to trick students, but rather to see whether they have assimilated the material. Questions that require some thought or interaction from students are superior to those that ask for a straightforward regurgitation of facts. But designing such interactive questions presents more of a challenge. The American National Standards Institute (ANSI) and the International Electrotechnical Commission (IEC) laser user standards allow the rigor of training programs to be commensurate to the potential hazard that the corresponding laser technology is expected to present. So, for example, there is no need for training to cover the bioeffects of ultraviolet radiation if all work will be performed in the near-infrared. While this seems reasonable, it does not allow training to easily adapt if new wavelengths or non-beam hazards are introduced to a partic- ular application. Further, it is unclear who will monitor how well the training corresponds to actual practice. The best way to approach the question of competency is laid out in Z136.8 Safe Use of Lasers in Research, Development, or Testing, which requires documented on-the-job training. This documentation puts a great deal of responsibility on the trainer or mentor. Some institutions have a system of qualified workers, where staff are only allowed to work on or perform set activities that can be expanded as their competency increases. Such an approach shares responsibility to ensure that new users have been trained for the equipment or activity, and that an experienced co-worker has observed them successfully applying best safety practices. This systematic approach can also be imperfect without the guidance of an external standard. Mentors are as capable as anyone to share bad habits that they were taught. They might also share “tricks” of the trade without explaining the logic behind them. This problem applies to both complex and simple laser operations, ranging from using sensor cards or viewers correctly to cutting fibers, to performing more complex alignment work with periscopes and irises. No one should work with or around Class 3B or Class 4 lasers without some orientation to the hazards of laser radiation, the proper control measures, and important laser technology concepts such as classification and maximum permissible exposure. Rather than simply testing short-term memory, the goal of those who are responsible for developing or overseeing laser training procedures is to develop a program and approach that promotes user competency. Experience has demonstrated that companies that prioritize training compliance numbers over the quality of training will encounter more accidents, incidents, and near misses. On-the-Job Training Steps There is no set timeframe for on-the-job training steps. The speed at which trainees will progress through these steps will vary with the skill and experience of both parties. When a trainee is ready to safely use laser equipment or perform certain functions on their own, their mentor will produce a form that both parties can sign to indicate that they both acknowledge that the trainee is ready for the next step. Refer to the Z138.8 Form appendix for a sample form. Suggested on-the-job training steps: • The mentor instructs the trainee on the work process and safety steps. • The mentor demonstrates hands-on skills to the trainee. • The trainee performs the activity to demonstrate competency. • The trainee provides feedback. • The mentor reviews the trainee’s independent work habits and performance.