EHS Administration, Training

Take A Closer Look at Your Safety Training Program

Have you thought lately about your safety training needs? Your workers need training in general safety and health precautions, as well as training focused on the specific hazards of their work and at the workplace.

Employee and supervisor safety training may help reduce workers’ compensation claims, and your insurer may offer resources to help with that.

Your workers need to understand the health and safety hazards inherent to their work and need to know how to identify hazards and understand the hazard controls—administrative and engineering controls and personal protective equipment (PPE)—used to protect them. If any of their work necessitates the use of PPE, your workers also need to be trained on how to wear and use it properly.

You probably also are aware that nearly every Occupational Safety and Health Administration (OSHA) standard—construction, general industry, marine terminal, and maritime—contains a training requirement. These include the agency’s standards for the following:

  • Chemical hazard communication (HAZCOM);
  • Control of hazardous energy (lockout/tagout);
  • Crawler locomotive and truck cranes, overhead and gantry cranes, powered industrial trucks, and servicing multipiece and single-piece rim wheels;
  • Emergency action plans and fire prevention plans;
  • Fire protection, fire brigades, fixed fire extinguishing systems and portable fire extinguishers, fire detection systems and employee alarm systems, and standpipe and hose systems;
  • First aid and medical services;
  • Flammable liquids and explosive and blasting agents;
  • Forklifts and other powered industrial trucks;
  • Occupational noise exposure;
  • Permit-required confined spaces;
  • PPE and respiratory protection;
  • Powered platforms for building maintenance;
  • Process safety management of highly hazardous chemicals and hazardous waste operations and emergency response;
  • Storage and handling of liquified petroleum gases and storage and handling of anhydrous ammonia;
  • Temporary labor camps;
  • Welding, cutting, and brazing requirements, as well as arc, oxygen-fuel gas, and resistance welding; and
  • Special industries’ standards like commercial diving operations; electric power generation, transmission, and distribution; grain-handling facilities; laundry machinery and operations; logging; pulp, paper, and paperboard mills; and telecommunications.

Agency inspectors will also look for training compliance in their enforcement of the General Duty Clause. While OSHA does not yet have a heat stress standard, the agency does have an indoor and outdoor heat-related hazards National Emphasis Program (NEP), unveiled April 13, that includes inspection procedures for training compliance.

An agency compliance safety and health officer (CSHO) will look for employee training on heat illness signs, prevention, and the importance of hydration; how employees are instructed to report signs and symptoms; and procedures for first aid and contacting emergency personnel.

Several OSHA regional offices have regional emphasis programs (REPs) for powered industrial truck compliance or forklift safety in warehouses. Inspection procedures include interviewing operators about training, as well as incidents and accidents, operator evaluations, repairs, and the handling of defective trucks. CSHOs also will interview employers or trainers to discuss training policies and procedures, training programs, and the frequency of training.

Hazard communication

OSHA’s HAZCOM Standard (29 Code of Federal Regulations (CFR) 1910.1200) has a requirement for employee and supervisor training in addition to the requirements for chemical labels and safety data sheets (SDSs). During an inspection, agency CSHOs will interview employees and supervisors to assess their knowledge of chemical hazards in the workplace and their understanding of how to read a chemical label, where to find and how to use SDSs, and necessary precautions.

Be aware that both host employers and temporary agencies are responsible for temporary employees’ HAZCOM training. Agency inspectors will cite both employers for violations. You also must show an inspector the documentation for the training provided to other employers’ employees at a multiemployer worksite.

OSHA inspectors will review documentation of the training elements of your written HAZCOM program. You must inform OSHA inspectors of who is responsible for training, how training is conducted, procedures for training new employees, and how retraining is offered when new hazards are introduced into the workplace.

Agency inspectors will check that all employees have received training in an in-house labeling system, if you use one.

Specific training standards

Some OSHA training requirements are so detailed that they have separate standards. For example, the construction industry fall protection standard (29 CFR §1926.501) is OSHA’s most frequently cited standard, but its standard for fall protection training requirements (§1926.503) is another frequently cited standard. The fall protection training standard was cited 1,556 times in fiscal year (FY) 2022.

Your fall protection training must be performed by a “competent” person who is well versed in fall protection measures and site-specific systems. Depending on the makeup of your workforce, training may need to be delivered in a language other than English.

Fall protection training must cover the nature of fall hazards in the work area and the proper procedures for erecting, inspecting, maintaining, using, and disassembling fall protection systems like guardrail systems, personal fall arrest systems, safety net systems, warning line systems, and safety monitoring systems.

Because those working at heights are at risk of being struck by falling materials and tools, training also must cover the correct procedures for the handling and storage of equipment and materials to prevent struck-by hazards. Workers also must be instructed on the limitations of mechanical equipment while performing roofing work on low-sloped roofs. All employees must be instructed on their responsibility for monitoring safety when fall protection systems are in use.

Moreover, there is a general construction industry safety training and education standard (§1926.21), but there also are separate training standards for the following:

  • Confined spaces (§1926.1207);
  • Cranes and derricks (§1926.1430);
  • Electrical safety-related work practices (§1910.332);
  • Scaffolds (§1926.454), shipyard fire protection (§1915.508);
  • Stairways and ladders (§1926.1060); and
  • Steel erection (§1926.761).

OSHA 10, OSHA 30 training

OSHA emphasizes safety training in its compliance assistance program, as well as its enforcement program, and its training outreach offerings include worker and supervisor training. The OSHA 10-hour training program is intended for entry-level employees, and the 30-hour program is intended for those with some safety responsibilities. Training covers the recognition, avoidance, abatement, and prevention of workplace hazards.

The 10-hour and 30-hour cards for workers who complete the training are referred to as the “OSHA 10” and “OSHA 30” cards.

Training is industry-specific—construction, disaster site, general industry, maritime industry—and is provided by OSHA-authorized, third-party trainers. Trainers provide workers and supervisors who complete training with OSHA 10 or OSHA 30 cards.

In addition to covering the recognition, avoidance, abatement, and prevention of workplace hazards, outreach classes provide an overview of OSHA worker protections under the Occupational Safety and Health Act and the agency’s standards. Training also covers employer responsibilities, workers’ rights, and how to file a complaint.

The Outreach Training Program is entirely voluntary, and the training does not satisfy the training requirements in any of OSHA’s standards. Also, the agency does not require that workers and supervisors have OSHA 10 and OSHA 30 completion cards.

However, some employers and state and local governments may require OSHA 10 or OSHA 30 completion as a condition of employment.

Exercise caution in acquiring training services; fraudulent trainers may advertise OSHA 10-hour or 30-hour training, but they are not authorized to issue the 10-hour and 30-hour cards. For example, a formerly authorized trainer once admitted to selling more than 100 fake OSHA 10 cards at $200 each. Because of this, OSHA maintains a watch list of suspended and revoked trainers the agency has found are not in compliance with the Outreach Training Program’s requirements. The list can be searched or sorted by name, city, and state.

Safety training, safety culture

Safety training can help reinforce a strong safety culture at your facility or jobsites, and basic safety training like the OSHA 10-hour course may be helpful in fostering employee safety awareness and compliance. Research has shown that training affects worker safety and health behavior, especially behavior surrounding ergonomic hazards.

Signs of a troubled safety culture can include failure to comply with your safety rules, policies, and procedures and risky worker behavior.

Employees “bending” or breaking workplace safety rules and procedures can have serious consequences, even the loss of a limb. For example, in a lockout/tagout case at a Walmart distribution center heard by the Occupational Safety and Health Review Commission, it was revealed that company and contract employees were regularly circumventing company procedures for entering an electrified monorail system (EMS), which consisted of trolleys to move pallets of merchandise within the warehouse.

Employees of Walmart and its logistic contractor crossed over fixed conveyors to enter the EMS. Employees also placed pieces of cardboard over the light curtains between loops of the EMS. Tragically, an employee servicing merchandise trolleys was struck by one, and a piece of machinery penetrated his leg.

The Walmart case points to the possibility of a “hidden” safety culture that can be starkly different from your stated policies, procedures, and employee rules. But, training may correct workers’ misconceptions about the safety culture and shore up compliance with safety policies, procedures, and rules.

You need to persist until you get to underlying safety issues, looking for hidden “mixed” messages and training accordingly. Look for common threads in your incident investigation reports, and hunt down employees’ jerry-built solutions that pose a safety hazard.

Training needs to be geared toward the intended audience, taking employees’ cultural and educational backgrounds into consideration, including literacy levels. In some instances, training may need to be delivered in a language other than English. Training resources in Spanish and other languages are available from OSHA, the National Institute for Occupational Safety and Health (NIOSH), and the labor union-supported Center for Construction Research and Training (CPWR).

Safety training is a key component of an overall safety and health management system, according to the American Society of Safety Professionals (ASSP). While training remains a key element of an effective safety and health management program, training alone is not enough to prevent workplace injuries and illnesses.

Other elements of an effective safety and health management program include safety observations, safety audits, job hazard analyses, and incident (or “near miss”) investigations.

Whether you’re concerned about reining in workers’ compensation claims, your recordable injury rate, or ensuring compliance with specific state or federal safety and health standards, safety training can help. You may find your safety training needs are addressed by programs offered by federal OSHA or state workplace safety and health agencies, labor union-affiliated groups, or your workers’ compensation insurance provider.