What are the OSHA Training Requirements?
Greg Daugherty, CSP, OHST, CHST
One question I often hear asked is, “Who does OSHA require to receive safety training and when?” The answer isn’t that difficult, but the execution can be time consuming and, in some cases, confusing.
The better question to start with is, “Why should employers provide safety training to their employees?” There are several ways to explain why, but these three best summarize:
- It’s good for business
- It’s good for employee
- It’s the law
Let’s start with the law. OSHA does not have a single training standard, although in each specific standard there are training requirements. The standards identify who must be trained, to what extent and sometimes even the number of hours of training required and who is authorized to deliver the training. Generally, OSHA training requirements state that:
- Employers must ensure that each employee, prior to the first exposure, is trained to identify the hazards and reduce the risks of their assigned tasks, the area they are working in, and the tools and equipment they will use.
- The training must be provided by a competent, or in some cases, a qualified person, in a manner that is effective and understandable to the employee.
There are detailed, and very specific, training requirements in some of the standards, such as 1910.120 Hazardous Waste Operations and Emergency Response (HAZWOPER). Within this standard, the employer must identify what category of responder the employee will be, and this dictates the number of hours of training that must be provided.
Another example is electrical training. Will the employee work with exposed voltage of greater than 50 VAC? If so, then qualified electrical worker training is required.
If the standard does not specify the amount of time or the exact subject matter to be provided in training, it is the employer’s responsibility to identify the hazards of the task, tool or area, and then provide training to the extent that employees understand the preventive actions to take in order to work safely.
“Who can train?” is another common question. The answer is almost always a competent person. This means a person, employee or third party who will effectively provide instructions on the OSHA standards, hazard recognition, risk reduction and ensure competency. Experience in adult education techniques should also be considered.
There are specific OSHA standards that require a certified and/or a qualified trainer. Examples are mobile cranes in construction and First Aid/CPR certifications. The standard will state when a certified or qualified trainer is required.
Other issues to consider for compliance, and to stay organized, with safety training are:
- Training matrix – Identify each task in the place of employment and then identify every training topic that each task requires.
- Frequency of training – Some training tasks require refreshers, such as bloodborne pathogen and hearing conservation, which require initial and then annual refreshers. There are several that require refreshers.
- Training tasks must be updated when changes to the work environment occurs – If a new chemical is introduced, then the hazard communication training must be updated to include that new chemical prior to first use or exposure.
- Recordkeeping – Always document and file all types safety training, regardless of length or formality.
During an OSHA inspection or investigation, the compliance officer will always ask for certain training records. It’s very important that the employer can provide the training record for the specific task and for the specific employee in question. Having training files organized by employee and by type of training task will save you time and potentially from citations.
Employers should always consider training as part of any incident investigation. as the training delivered? Was it accurate? Was it understood? Did we follow-up on implementation? Very importantly, did we audit the process for effectiveness? And was the employee adhering to the training given?
OSHA provides a helpful publication — OSHA2254 — that answers many of the safety training questions by standard and by task.
Providing compliant, effective and understandable safety training is good for business, it is good for the employee, and it is the law. Safety training is an investment in the business and in the employee, that if managed as an important program will provide a return on that investment.
Greg Daugherty, CSP, OHST, CHST
With over 30 years experience in occupational safety and health compliance in manufacturing, construction, oil & gas exploration and mining, Greg is a highly effective consultant, providing guidance and practical solutions for OSHA compliance and best practices.