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Some specific standards may have more extensive requirements for training recordkeeping, but here are the basic records you should have for any training that your workers receive.
Training Certification
At its most basic, a training record should document:
- The names of any employees who were at the training session. Preferably, they should sign the record.
- The name, title, and qualifications of the trainer.
- The date(s) of training.
- The length of the training session. Was it a 15-minute toolbox talk or a 3-hour training session?
- The training format(s) (live instructor, remote instructor, video or computer-based, etc.).
- A record of the training content (more on this below).
- Evaluation results.
Training Content
It’s important to keep a record of what the training covered. In some cases, the standard specifies what the training must cover. In other cases, a record of what was included can protect you against a charge that you never informed workers of a specific hazard or protective measure.
Keep a record of:
- Written materials provided to workers. Some standards, like the bloodborne pathogens standard, require that you give workers a copy of the standard itself. In other cases, you may want to give workers a copy of safety data sheets (SDSs), operating instructions, lockout/tagout (LOTO) procedures, or other paper materials. Keep copies of these handouts with your training records.
- Hands-on or practical training. If workers tried on protective gear, operated a piece of equipment, or practiced their LOTO procedures using actual equipment, make sure that goes into your records. Again, some standards require this “hands-on” or practical portion—for example, the powered industrial truck standard requires that workers be trained on the specific equipment they will operate, so be sure to include in your records a list of the specific equipment they operated during their training session.
- Video or computer materials used. If you’ve used specific computer-based or video content, especially content from OSHA, the U.S. Chemical Safety and Hazard Investigation Board, or another government agency, you’ll want to be able to show that information to an inspector.
When to Toss the Records
Keeping records takes up space, even if you keep them electronically. How long must you keep training records? In general, OSHA recommends that employers keep training records for 5 years. However, the requirements within specific standards vary greatly. For example:
- The bloodborne pathogens standard requires that records be retained for 3 years.
- The asbestos standard requires that training records be kept for the duration of each worker’s employment plus 1 year.
- The LOTO standard for shipyard employment requires employers to retain training records until they are replaced by a new training record.
If dealing with retention requirements for individual standards is too cumbersome, make arrangements to keep records for the duration of a worker’s employment plus 3 years, and you should be covered.
Need more information on training requirements? Safety.BLR.com® has all the specifics.