Must I Document ALL of My Safety Training?

Yes, you do, even if OSHA doesn’t require it. More than 100 separate OSHA rules feature training requirements. Some of those standards also require you to certify that training has been successfully completed and that employees have learned the skills and information they need to work safely.

For example, OSHA’s process safety management standard (29 CFR 1910.119) requires documentation of training, as does the powered industrial truck standard (29 CFR 1910.178). And DOT’s hazardous materials transportation regulations (49 CFR Parts 171-180) require you to keep records of training conducted in the preceding 3 years. But even when documentation isn’t expressly required in the regulations, as a practical matter, you should keep records of all safety training. As OSHA points out, documentation that proves training has been conducted and that employees have successfully completed the training provides evidence of your good-faith compliance with OSHA standards generally.

Documentation can also supply an answer to one of the first questions an OSHA inspector will ask when investigating a workplace injury: “Was the injured employee trained to do the job?”

• Documentation provides additional benefits. For example, your safety training documentation will help you:
• Keep up to date with annual or periodic training requirements included in state and federal government regulations
• Maintain efficient training schedules and select appropriate trainers and trainees
• Identify at a glance which employees have already been trained and which training topics they have completed
• Decide if employees are qualified to work safely in their assigned jobs
• Determine retraining, refresher training, or additional training needs
• Diagnose accident and injury patterns to see where additional training may be required or where current training is failing to achieve goals

If you don’t already have a centralized training log, you need one now. Your safety documentation should be kept in such a way as to make it easily available to those who need to refer to it. Keep these tips in mind:

• Your safety training log can be maintained either as paper or computer files, whichever is easiest. But if you use computer files, make sure they’re backed up.
• Include the name and department of each employee trained, the date(s) of the training session(s), the name of the trainer(s), the topic of the training session, the length of the session (to show how much time was spent on the topic), and frequency of training required.
• Keep all training records accurate and up to date.

• Have employees sign an attendance sheet or some other document that proves they attended the session. Also, have them sign any evaluations, such as quizzes, skill proficiency tests, and so on.
• Document your evaluation method by keeping an individual dated record for each worker that lists the methods you used to verify that the employee learned what was required in training.
• Document when additional training is required to achieve proficiency, and include the date on which such additional training took place.

Why It Matters…

• Failure to meet government recordkeeping requirements can result in citations and fines. 
• Unless you know who needs training, in what, and when, your safety training program will not be effective.
• Training documentation ensures that employees have the skills and knowledge to perform their jobs safely and avoid accidents and injuries.

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