Do Generic Safety Training Courses Meet OSHA’s Requirements?

Do Generic Safety Training Courses Meet OSHA’s Requirements?

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This is a question we hear all of the time:  Do generic on-line, videos, & CD-ROM safety training courses meet OSHA’s standards?

In other words, if your company uses these generic training platforms will it suffice to protect your employees from your specific workplace safety hazards (hint, hint) and protect your company from OSHA fines. Etc.?

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OSHA’s guidance on this issue isn’t crystal clear but we did a little research and determined that the answer is a definitive “no,” generic safety training courses doen’t meet OSHA’s standards.

The rest of this blog post will explain why.

Many companies choose to use generic safety training options for a variety of reasons including cost and convenience, not realizing that this decision can end up putting their employees and business at serious risk.

Let’s begin by considering the following question, which an OSHA inspector will probably ask during an investigation if your company experiences a serious injury or fatality:  “Did the employee receive adequate training to do the job?” (We actually found this on OSHA’s website)

It’s a very broad and vague question, and therefore scary for any employer who isn’t super confident about their safety training program.

So this begs the question: what does OSHA consider to be “adequate” safety training?

OSHA uses 4 primary criteria to make this determination.  A company’s Health and safety training must:

  • Be understandable
  • Meet the intent of the specific OSHA standard
  • Be documented
  • Address site-specific/workplace hazards

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Let’s take a quick look at each of these criteria:

  • Understandable:

This criteria basically boils down to a few key issues.  The training must be delivered in a language that the trainee understands (ie: don’t train a Spanish                 speaker in English and expect them to understand the training), the employees must be able to ask questions and get answers from a qualified trainer, and             comprehension should be tested and verified.

  • Must meet the intent of the OSHA standard:

Each OSHA standard contains very specific information which must be included and communicated in the associated training.  In other words, the training            must include all of the compliance related information.

  • Must be documented:

OSHA states that training must be “certified,” which essentially means that that the company maintain training records which include: topic trained,                        attendee printed names and signatures, and date of the training session.

  • Address site-specific/workplace hazards and job duties:

The training must address a company’s specific and unique workplace hazards.  Examples include site specific hazardous chemicals, equipment specific                  Lockout/Tagout procedures, fall hazards, respiratory and noise hazards, etc.

Now that we’ve discussed these criteria, let’s circle back to the original question which is whether or not generic training courses meet these standards, and we’ll do it one at a time:

  • Understandable:
    • Generic training can easily be delivered in the correct language, and might include a quiz to test comprehension, but a video or CD-Rom course can’t answer employee questions.
    • So, no, generic training doesn’t meet this criteria.
  • Must meet the intent of the OSHA standard:
    • Generic training often includes all of the basic compliance information.
    • So, yes, generic training can meet this criteria.
  • Must be documented:
    • Some generic training courses, especially those offered on-line, can include some sort of training documentation or certification.
    • So, yes, generic training can meet this criteria.
  • Address site-specific/workplace hazards and job duties:
    • This criteria is where generic training courses really fail to meet OSHA’s standards. It’s impossible for a generic platform to include all of the unique, site-specific workplace health and safety hazards at any given company.
    • So, no, generic training doesn’t meet this criteria.

In summary, generic training resources can only meet 2 out of OSHA’s 4 training criteria, which means that these resources cannot be relied on to protect your employees and company from related risks.

So what is a company supposed to do?  In summary, a company must figure out a way to develop and deliver customized safety training that meets all of these requirements, especially the company’s specific workplace hazards.

There’s really only 3 options:

  1. Hire an experienced and qualified safety professional who can adequately assess your company’s specific workplace health and safety hazards.  These kinds of professionals are hard to find.
  2. Hire a 3rd party safety consulting company who can provide on-site, OSHA compliant safety training.
  3. Subscribe to an on-line OSHA safety training platform that provides customized training to address your company’s site specific hazards.

Berg Compliance Solutions can help with options 2 & 3 above.

Give us a call at 512-457-0374 or click here to contact us.

Thanks for reading and feel free to contact us with questions or concerns.

By |2019-04-28T17:38:50-05:00April 25th, 2019|OSHA Texas Laws & Regulations, Safety Training, Texas OSHA Compliance|Comments Off on Do Generic Safety Training Courses Meet OSHA’s Requirements?

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