OSHA safety training requirements often raise lots of questions. Here are some recent questions we’ve received from subscribers to BLR’s safety and health website Safety.BLR.com.
Q. Are there any regulations on how often you must have safety meetings?
A. Federal OSHA has no regulation that states how often you must have safety meetings. There are regulations that mandate training on a schedule such as Bloodborne Pathogens (29 CFR 1910.1030) training, which is required annually.
Other general industry standards that require annual training include:
- Asbestos—29 CFR 1910.1001
- Exposure and Medical Records—29 CFR 1910.1020
- Fire Brigades—29 CFR 1910.156 (quarterly training required for interior structural firefighters
- Fire Extinguishers—29 CFR 1910.157
- Fixed Fire Extinguisher Systems—29 CFR 1910.160
- Grain Handling—29 CFR 1910.272
- HAZWOPER—29 CFR 1910.120
- Machine Guarding—29 CFR 1910.217 and 218
- Noise—29 CFR 1910.95
- Respiratory Protection—29 CFR 1910.134
- Toxic Substances—29 CFR 1910.1003, 1017,1018, 1025-1029, 1043, 1045-1048, 1050
Then there are two standards that require training every 3 years: Process Safety Management (29 CFR 1910.119) and Powered Industrial Trucks (29 CFR 1910.178).
No time to write safety meeting materials? You don’t need to with the 50 prewritten safety meeting modules in BLR’s Safety Meeting Repros program. All meetings are ready to use, right out of the box. Try it completely at our expense! PLUS get a free report! Get the details.
Q. Can PPE training (safety glasses and ear plugs) be taught online through the company intranet or does it have to have a live instructor?
A. PPE training for safety glasses and ear plugs can be taught on line through the company intranet, as long as the employee can demonstrate the proper use of PPE. In other words, once the PPE training is completed you have to verify that the employee knows how to use it.
Q. What’s the relationship between OSHA, EPA, and DOT training requirements?
A. EPA, OSHA, and DOT each have separate training rules, but there is often overlap among the various training requirements. For example, an employer may have workers managing hazardous waste and have the same workers preparing hazardous materials for transportation. In this situation, EPA’s hazardous waste rules, OSHA’s Hazardous Waste Operations and Emergency Response (HAZWOPER) requirements, and DOT’s hazardous materials training standards would all apply. Therefore, it is important to be familiar with each agency’s training rules. In some cases, OSHA and EPA have separate training requirements for the same operation, process, or substance. It can be difficult to determine which rule applies in a specific situation. Check with the agencies if you have further questions.
To contact OSHA with questions, go to http://www.osha.gov/html/Feed_Back.html for information about e-mail, phone, and written inquiries, or contact your OSHA area office. For contact information about area offices, go to http://www.osha.gov/html/RAmap.html.
To contact EPA with questions, go to http://www.epa.gov/epahome/hotline.htm for a list of phone numbers and e-mail addresses for specific environmental issues.
To contact DOT with questions, go to https://ntl.custhelp.com/app/ask or use the e-mail question form at https://ntl.custhelp.com/app/ask.
Examine Safety Meeting Repros completely at our expense. Send no money. Take no risk. Get a FREE report. Get more info.
Q. When is confined space training required?
A. According to 29 CFR 1910.146(g), employees who work in confined spaces must be trained on the safe performance of their duties before initial assignment, before a change in assigned duties, upon a change in operations that presents a new hazard, when there are deviations in procedures, and when employee knowledge is inadequate.
Q. The only medical records we keep are those for initial employment and what is required for workers’ comp for employees that have workplace accidents. Must we do the annual training listed under 29 CFR 1910.1020?
A. 29 CFR 1910.1020 applies to employees exposed to hazardous substances and does not apply to work situations where employees are only exposed to just safety hazards such as slips, trips, cuts, etc, or one-time first aid. So annual training is not necessary unless you employees are exposed to hazardous substances.
If employees are exposed to hazardous substances, then the training requirements of 29 CFR 1910.1020(g) do apply and workers must be trained upon initial employment and informed about the existence, location, and availability of all exposure and medical records. You must also identify personnel responsible for maintaining and providing access to the records and explain employee rights of access to records. Annual refresher training is required.