The time is approaching when you may need to make safety related training plans and projections for the upcoming year. Such training may reduce costly illnesses and injuries in your workplace. While there may be some dispute as to the exact return on investment for such training there can be no doubt that it is required by numerous OSHA standards.
There are over 100 training requirements found in OSHA’s standards. Many of them are very specific in setting out the nature, frequency, scope, etc., of such training while others are more general. For instance, some standards require that an employee allowed by an employer to perform certain tasks must be “certified, qualified, or competent” in the performance of that task.
Virtually all of the OSHA standards at the top of the most frequently violated standards each year include a training provision. Not infrequently, OSHA press releases announcing issuance of citations with significant monetary penalties include charges of training deficiencies. You may also be sure that a very important question to be answered following a serious work-related accident will involve the victim’s relevant training.
Some OSHA training standards call for an annual review or refresher training. For example, the confined space entry standard requires that those employees assigned rescue duties practice a permit entry at least once every twelve months. Where an employer has provided portable fire extinguishers for employee use, training in their use is required at least annually. Employees with occupational exposure to blood-borne pathogens must receive annual refresher training. Employees exposed to noise levels at or above 85 decibels must receive annual training regarding the effects of noise and the means of protection. Employees must receive yearly training that is comprehensive and understandable when their duties require them to use respirators. Most of the chemical- specific health standards such as those for asbestos, lead, formaldehyde, etc., call for annual training.
A number of standards call for employee safety training upon initial assignment to the job and retraining when there is a change in potential exposures. For example, the hazard communication standard requires further training anytime a new physical or health hazard is introduced to the employee’s work area. Refresher training is also required when a powered industrial truck operator is noted by observation or evaluation to be operating unsafely, or is involved in an accident, or when workplace conditions change that might alter truck operations. Finally, employees required to use personal protective equipment (PPE) in their jobs must be retrained when the employer has reason to believe the employee does not have adequate understanding or skill to properly use the PPE.
Some of OSHA’s training requirements call for written documentation and some specify a retention time. For example, the blood-borne pathogens standard requires a record of training must be kept for three years. A certification of training must be kept for employees required to use PPE but no time is set for retention. The lockout/tagout standard requires a certification of training without specifying a retention time. Whether or not OSHA requires a specific training record, we strongly advise that an employer keep a record of all safety and health training. At the very least it may serve as evidence of an employer’s ongoing efforts to comply with standards and promote a safe workplace.
OSHA Publication 2254, “Training Requirements in OSHA Standards and Training Guidelines,” is an excellent source for an employer to access a worksite’s needs and requirements. This document may be viewed, downloaded, or ordered by going to the publications topic of OSHA’s website www.OSHA.gov or by following this link: OSHA 2254 1998 (Revised).