If you have a third-party consultant with an office space onsite, you may have a lot of questions about how this employee needs to receive appropriate safety training. How do you classify him or her when it comes to required trainings such as Hazard Communication? Since he or she isn’t a temporary employee, do they require the same training as a regular employee?
Here’s an answer for you, courtesy of experts at Enviro.BLR.com®:
The employer of the consultant (i.e., the third party) and the company hiring the consultant (i.e., your company) are jointly responsible for safety training. According to OSHA, the primary responsibility for providing the training is the consultant’s direct employer. Your company hiring the consultant would provide the site-specific elements of training because your company has the site-specific knowledge about specific hazards and control measures.
See the OSHA interpretation letter that covers requirements for training consultants at https://www.osha.gov/laws-regs/standardinterpretations/2015-06-11.
As explained in the letter, the type of training the consultant will receive depends on the potential hazards they may encounter and on the OSHA standard(s) that apply. For example, hazard communication training may be required if the consultant is exposed to hazardous chemicals as part of his/her job duties.
Note: This question was answered by experts at Enviro.BLR.com.