Let’s Talk Workplace Safety Training Programs
So what exactly are OSHA’s health and safety training requirements?
Unfortunately it’s not a simple answer because OSHA’s safety training regulations are actually fairly extensive, but we’ve done our best to summarize the most important points below.
Before getting into the details, let’s quickly cover some very common mistakes that companies make when trying to manage safety training which can end up leading to lots of problems like serious injuries and major fines:
- Only using generic on-line or video safety training
- Failure to document training
- Failure to determine which OSHA training topics apply
- Failure to customize training to address company specific health and safety hazards
- Failing to train new employees on applicable topics before putting them to work
- Assigning inexperienced staff to deliver safety training
- And worst of all, not delivering any safety training at all….
Now let’s talk about how to correctly manage employee health and safety training to meet OSHA standards.
How to determine which topics to train:
- Begin by identifying all of your company specific health and safety hazards, which you’ll then use to determine which OSHA standards apply to your company’s operations.
- Then develop a training plan which includes the training topics for each one of these standards. In other words, each OSHA Standard has a corresponding training requirement. For example, the Fall Protection Standard includes a training requirement that must address all fall hazards at a particular company.
Other common standards and topics include Hazard Communication (Chemical Safety), Personal Protective Equipment, Emergency Response & Fire Prevention, Lockout/Tagout (both “Authorized” and “Affected”), Electrical Safety, Confined Spaces, Respiratory Protection, Hearing Conservation, and the list goes on.
- The number of Standards that must be trained depends on the company’s processes & hazards, but it’s common for a company to be required to train between 8-12 topics to each of its employees, depending on their duties.
- Training topics should be matched with specific job tasks, employee responsibilities and/or departments. It is common to use a “training matrix” to organize the training plan. Topics should address the specific health and safety hazard exposure per area. In other words, all employees don’t necessarily need to be trained on all topics, only those topics that impact their scope of work and hazards they face.
What needs to be included in each topic?
- Relevant OSHA standard technical information
- Training content requires 2 parts:
- Part 1 includes all of the “technical” information included in the specific standard.
- Part 2 includes “customized” company specific information. Examples include information about specific hazardous chemicals at a company, how to execute Lockout/Tagout procedures, how to don and doff PPE, and more.
- Some standards require both written and/or performance evaluations. This is especially true with forklift and crane operator training.
How long does it take to train each topic & what’s the frequency of training?
- All new employees MUST be fully trained before they are put to work.
- Each topic typically takes a minimum of 30 minutes to train, but most take between 45-60 minutes in order to address adequately, and some topics take longer.
- Some OSHA standard training requirements are “one-time,” but many are recurring and are mandated to occur each year. Even those that aren’t mandated to occur annually are always “recommended” by OSHA to occur each year and employers who take health and safety seriously should do so.
- Training frequency requirements and employee turnover makes training a “never ending process.”
Other Safety Training Considerations:
- Who should develop & deliver training?
- Training session should be delivered by an experienced and qualified trainer who has the technical knowledge and expertise to train the topic. Not only does this ensure that all aspects of each topic are trained, but it also ensures that the trainer is able to address questions from the audience. Ideally the trainer also has an “approachable” personality who can invite participation and engage the audience. Nobody wants to be trained by a “robot” or unqualified person, it’s a waste of time for everyone involved.
- Why doesn’t “generic” safety training meet OSHA standards?
- Many companies opt to utilize generic, “on-line” training resources or videos. This is acceptable, however it prevents the opportunity for employees to ask and receive answers to their questions.
- OSHA has a standard requiring that employees “must understand and be able to use their training,” but if they’re unable to ask questions, and get answers, then typically this standard is not met.
- And again, the content must be customized to your operations and generic training simply doesn’t include customization.
- Employers must create and maintain training records, because as far as OSHA is concerned, “if there isn’t a record, then it didn’t occur.” It’s recommended that companies create a sign-In sheet for each training session, which includes the topic trained, the instructor’s name, and then has lines for each employee’s printed name (legible), signature and date. This meets OSHA’s “training certification” standard. Always keep a copy of the training record on file.
- Be aware of those “Experienced” new hires. Do not assume that experienced employees were trained properly in their previous employment. Always remember that you need training records to document that proper training has occurred. And be aware that less desirable new employees may bring their bad safety habits into your company.
- Many employers make the mistake of believing that occasional (weekly or monthly) 10-15 minute “tailgate” training sessions meet all OSHA safety training requirements. These short sessions are typically designed to address a single hazard, or aspect of a particular hazard, and their overall purpose is to help “keep safety top of mind” and maintain or build the culture of safety in a company. These short training sessions are great for these purposes, but they don’t meet the formal OSHA standard training requirements as described above, and therefore should not be considered a substitute for those requirements.
In summary, workplace safety training programs are extensive and require considerable expertise, thought and ongoing management effort in order to meet OSHA compliance requirements.
This process can be extremely challenging, especially for small companies who often lack the expertise, time and resources needed to keep up.
Berg Compliance Solutions specializes in helping small companies to manage OSHA compliance and risk, and offers a wide range of
CLICK HERE or Call 512-457-0374 to learn more about how we can help with OSHA compliance training needs