Many OSHA standards have specific requirements concerning training content and frequency. Today and tomorrow, we review some frequently asked questions about these requirements.
Q. Could you please clarify OSHA’s interpretation of training requirements and what is expected when training must be conducted “at leas annually”?
A. “Whenever OSHA standards require that employee training be conducted ‘at least annually,’ OSHA interprets this to mean that employees must be provided retraining at least every 12 months (i.e., within a time period not exceeding 365 days),” says Judith A. Ruddy, managing editor—safety at Business & Legal Resources, Inc. (www.blr.com).
This annual training need not be performed on the exact anniversary date of the preceding training but should be provided on a date reasonably close to the anniversary date, taking into consideration the company’s and employees’ convenience in scheduling, Ruddy says.
“Keep in mind that the term ‘at least annually’ is generally regarded as indicating that circumstances that warrant more frequent training may occur. It is extremely important that employees are trained to protect themselves from all known workplace hazards, including new hazards which may result from changes in work practices, procedures, or tasks.”
OSHA training requirements typically include:
- Hazards of the work assignment
- Safe performance of the operation
- Proper use of any required PPE
- Basic information about relevant OSHA regulations
- Application of training to the particular worksite and the equipment being used
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Q. Does OSHA have any additional requirements (beyond annual or recurring refresher training) for employees who have left the company and then returned?
A. OSHA does not address training requirements for someone who has left a company and returned. If the company has records of previous training, the process or procedure being trained on has not changed, and refresher training is given in the correct time frame, it seems reasonable that this would meet OSHA requirements. However, your company may have other policies regarding training of rehired employees.
Q. Is online training an acceptable method of EHS training? Do I have to have hands-on training to complement the online training?
A. Online training is an acceptable method of EHS training. Some topics such as forklift and HAZWOPER also require hands-on training. Check the regulations governing the particular type of training you are conducting.
Q. Who is ultimately responsible for the safety and training of rental equipment: lifts, booms, etc.?
A. It doesn’t matter whether the equipment is owned or rented, OSHA requires a safe workplace and all safety compliance and training requirements apply to all equipment—rented or owned. The employer is responsible for the safety of its employees.
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Q, Is there a requirement (regulation) that requires employees receive general training when using a tool or machine for the first time?
A. There are specific training requirements for employees who use power presses—1910.217 and forging machines—1910.218. There are no specific requirements for training for other machines and tools. However, the General Duty Clause requires employers to provide a safe and healthful workplace. The prudent employer would provide training in those areas where there are not specific OSHA regulations.