OSHA SAFETY TRAINING BASICS:

OSHA

SAFETY

TRAINING

BASICS:

What You

Need to Know

WHITEPAPER

OSHA SAFETY

TRAINING BASICS:

What You Need to Know

WHAT TRAINING IS REQUIRED?

Employee training is a common topic of concern and discussion among safety

professionals. The subject generates numerous questions like:

What training is required and what do we need for our industry?

What does OSHA expect in a training program?

What conditions trigger refresher training?

What are the risks of noncompliance?

Are our training records acceptable?

We’ll take a look at each of these and give you some practical information and ideas to help

you get and stay in compliance with OSHA’s training requirements.

This is one of the most basic questions asked. The rst place to look for training

requirements is in the OSHA standards. But which OSHA? Many states and territories have

been approved by OSHA to operate their own safety and health programs.

These state-plan states must have standards that are at least as effective as OSHA’s rules,

but they may have additional requirements that could involve employee training.

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If you’re in one of these state-plan states, you’ll need to meet the training

requirements in your state. Many of these states adopt Federal OSHA rules “as is,”

but this isn’t always the case.

Also, state plans cover public employers (state-, county-, or local-government

employers) as well as private-sector employers. Federal government employers do

have to comply with OSHA. To make matters more complicated, there are several

state plans that apply only to public-sector employers. Private-sector employers in

these states must comply with Federal OSHA.

WHAT TOPICS ARE COMMONLY TRAINED ON?

Now that you know where to look for the requirements, what are some of the topics

that contain required training? Some of those topics include hazard communication

(including Safety Data Sheets and labeling), emergency action plans, injury and

illness reporting, powered industrial trucks, permit-required conned spaces, fall

protection, respiratory protection, and electrical safety.

WHAT TRAINING DO WE NEED FOR

OUR INDUSTRY?

OSHA does have a few industry-specic standards that do take precedence over

other general industry standards. These are listed below:

Pulp and paper mills

Logging operations

Textile mills

Telecommunications

Bakeries

Electric power generation

Laundries

Grain handling

Sawmills

Alaska

Indiana

Minnesota

South Carolina

Arizona

Iowa

New Mexico

Tennessee

California

Kentucky

New Jersey

Utah

Connecticut

Maine

New York

Vermont

Hawaii

Maryland

North Carolina

Virgina

Illinois

Michigan

Oregon

Washington

STATE-PLAN

STATES

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Even though these standards do set industry-specic requirements, they typically

reference the other general industry standards, too. The point is, if you’re trying to

identify your OSHA training needs, your industry probably isn’t the place to start.

Whether or not a particular OSHA standard applies depends on your facility’s

activities and the hazards faced by your employees, rather than the industry your

business is in. For example, if any of your employees are required to provide rst

aid as part of their job duties, those employees would need training in bloodborne

pathogens.

Keep in mind some OSHA standards require annual training and retraining.

DO WE HAVE TO HAVE MONTHLY SAFETY MEETINGS?

Another common question relates to having monthly safety meetings. OSHA

doesn’t require employers to hold regularly scheduled training or other general

safety meetings. However, according to OSHA information on safety and health

management programs, employers should “regularly communicate with employees

about workplace safety and health matters.”

Even though regular safety meetings are not required, they’re a good way to keep

the lines of communication open. And, if you have to cover numerous topics for

annual training, you might nd it more convenient to discuss one topic each month.

WHAT DOES OSHA EXPECT IN A TRAINING PROGRAM?

Employers often ask about training program content or how training should be

conducted. Some of the most common questions follow.

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ONCE YOU DETERMINE THAT

AN OSHA RULE APPLIES TO THE

OPERATION, REVIEW THE RULE

FOR ITS EMPLOYEE TRAINING

REQUIREMENTS.

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IS IT OK TO USE COMPUTER-BASED TRAINING PROGRAMS?

OSHA interpretations indicate that computer-based and video-based

training used alone is not enough. The agency expects computer-

based and video-based training to be supported by qualied trainers

who can provide answers to the trainees’ questions at the time the

questions arise.

OSHA also says training should provide “hands-on” demonstrations

and opportunities for trainees to practice using equipment and

following procedures. It’s clear that OSHA expects computer-based

training to be only a part of a training program.

WHAT ABOUT REFRESHER PROGRAM CONTENT?

Refresher training should:

Highlight and summarize the important parts of the topic,

Report on the group’s progress,

Emphasize any changes that have occurred since the previous

training was held, and

Give you the opportunity to introduce more advanced material.

There’s no general requirement that applies to all refresher training. If

a standard has details on the content of refresher training, be sure to

follow those requirements. For example, the lockout/tagout standard

says that retraining “shall…introduce new or revised…methods and

procedures, as necessary.”

HIGHLIGHT AND SUMMARIZE

REPORT ON PROGRESS

EMPHASIZE CHANGES

INTRODUCE MORE

ADVANCED MATERIAL

REFRESHER

TRAINING

SHOULD:

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WHAT ARE THE RISKS OF NONCOMPLIANCE?

No one wants to be out of compliance, but if you’re ever tempted to cut costs by

sidelining training, consider the consequences.

If you don’t provide training, you’re at risk for some hefty OSHA nes. Training

violations are typically cited as serious violations. OSHA recently increased the

maximum ne for a serious violation from $13,653 to $14,502.

Of course, the other risk of noncompliance is a workplace injury, illness, or fatality.

When someone isn’t sure of what they’re doing, they have an increased risk for

injury. Injuries and illnesses come with costs that are likely to be higher than OSHA

nes. The obvious direct costs include medical bills, repairs to any damaged

equipment, product losses, and costs to hire and train replacement workers.

You also need to consider the indirect costs, such as decreased morale and

productivity in coworkers, increases in your workers’ compensation premiums, and

lost business contracts due to having a higher experience modication rate. Plus,

your reputation in the community and industry can take a hit if the injury, illness, or

fatality is publicized.

WHAT ARE OSHA’S REQUIREMENTS FOR

TRAINING RECORDS?

There is no one OSHA requirement for training records that applies in all situations.

The requirements vary from standard to standard. Many rules don’t include training

record requirements.

Here are some examples of when OSHA does require training records:

The permit-required conned space standard says that training certications

must include each employee’s name, the signatures or initials of the trainers,

and the dates of training. OSHA doesn’t set a record retention time.

OSHA increased the

maximum ﬁne for

a serious violation

from $13,653 to

$14,502.

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Under the asbestos standard, employers have to keep training records for one

year beyond an employee’s last date of employment. The standard doesn’t

detail the content of the records.

The bloodborne pathogens standard states that training records must include

the dates of training, the contents of the training sessions, the names and

qualications of trainers, and the names and job titles of those trained. You have

to keep these records for three years.

Make sure you check the training records in each applicable rule to nd out if

training records are required, what OSHA wants you to include on the training

records, and how long OSHA expects you to keep the records.

Even when training records aren’t required, you may want to keep them anyway as

a way to help organize your training program. Consider including the employee’s

name, the date of the training, the name of the trainer, and the topic covered.

HOW LONG DO WE HAVE TO KEEP TRAINING RECORDS?

Sometimes a rule will tell you how long to retain the training records, but more often

than not, there is no record retention requirement.

If a rule doesn’t specically require a record retention time, an employer could set

a policy to retain training records for a certain number of years or even for a period

after employment has ended. This would be up to the employer.

Keep your training records up to date. If OSHA visits, you must be able to produce

the record from the employee’s most recent training.

HOW DO OSHA COMPLIANCE OFFICERS USE TRAINING RECORDS?

The main reason for keeping training records is because OSHA requires them. But

what does OSHA look for in training records, and how does a compliance ofcer

(inspector) use them during an inspection?

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OSHA inspectors will ask to see your training records when the OSHA rule in

question requires you to keep the records. They’ll pay attention to how much trouble

it is for you to nd the records. This gives them an indication of how well organized

your training program is. When you can produce the records without delay, you

show that your company does pay careful attention to training.

Aside from training records, perhaps the most important method OSHA compliance

ofcers use to evaluate your compliance is to ask employees about the training

they’ve received. If workers praise the training program, you’ll be in good shape. If

many employees don’t remember being trained, or give negative feedback about

the training, OSHA will take a closer look at:

Your training records,

The materials you use to train,

The methods you use to provide training, and

The knowledge of your instructors.

HOW CAN WE USE TRAINING RECORDS?

After you’ve prepared the training records, don’t just leave them to sit in the

le. Training records have several uses during day-to-day operations. Use your

records to:

Help determine when annual refresher training is required.

Keep track of an employee’s qualications for job assignment. If you see

someone doing a job that requires specialized training, you can easily check to

be certain they’ve received that training.

Help you identify workers who have a solid training history and may be ready to

handle more specialized training for jobs with more responsibility.

THE INSPECTOR WILL

SEE HOW COMPLETE

YOUR RECORDS

ARE. INCOMPLETE

RECORDS POINT TO

DISORGANIZATION, AND

MAY BE AN INDICATION

OF AN INCONSISTENT

TRAINING PROGRAM.

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You aren’t the only one who wants to know if the training program is

effective. You should be prepared to periodically submit reports to

management on:

What training has taken place,

Who’s been trained,

How much time was devoted to training,

What training materials are available,

How well training objectives have been met,

How training has improved safety, and

What training is planned for the future.

USE YOUR TRAINING

RECORDS TO:

DETERMINE WHEN

TRAINING IS REQUIRED

KEEP TRACK OF EMPLOYEE

QUALIFICATIONS

IDENTIFY EMPLOYEES WITH

TRAINING HISTORY

LEARN MORE

If your business already has its

own Learning Management System

(LMS), you can still take advantage of

J. J. Keller® TRAINING. License our

award-winning courses and videos to

use on your current platform!

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WRAP UP

A GOOD WAY TO APPROACH SAFETY TRAINING,

WHETHER REQUIRED BY AN OSHA RULE OR NOT, IS TO:

EXPLAIN THE HAZARDS.

LET EMPLOYEES KNOW WHAT YOU’RE DOING TO CONTROL THE HAZARDS.

SHOW EMPLOYEES WHAT YOU WANT THEM TO DO TO STAY SAFE.

MAKE SURE THE EMPLOYEES UNDERSTAND WHAT YOU’VE TOLD THEM.

FOLLOW UP WITH OBSERVATIONS TO MAKE SURE EMPLOYEES ARE

PUTTING THE TRAINING INTO PRACTICE.

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ABOUT J. J. KELLER & ASSOCIATES, INC.

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ABOUT THE AUTHOR

MARK STROMME, EDITOR,

J. J. KELLER & ASSOCIATES, INC.

Mark Stromme is one of the lead safety editors at J. J. Keller & Associates, Inc. He specializes in OSHA

construction and general industry safety and is an authorized OSHA Construction Outreach Trainer. At

J. J. Keller Mark researches and develops content for a variety of proprietary products, including

training videos, newsletters, handbooks, manuals, and software. His work has also appeared in ISHN,

Occupational Health & Safety, Workplace HR & Safety, BIC, EHS Today, Modern Contractor Solutions,

and Tow Professional. Mark contributed to the OSHA 5810 – Hazards Recognition and Standards Training

for the Oil and Gas industry and speaks frequently to industry groups about safety and regulatory issues.