Safety Training Information: What's Required by OSHA?

​How much do you know about Safety training requirements per OSHA? I am not discussing best practices or what you do at your company. Just the basics! OSHA is the regulatory requirement, or the bar if you will. That means you can do the bare minimum to meet the standards. It is the baseline that you must meet under regulations. (it is step one of program management). Step two: This is where Consensus standards may be applied, including industry or equipment specific guidance. The Types of standards that apply may be A-B1, B2, or C Type standards. Some of them may be referenced by OSHA, making them more enforceable. So, you must understand their application.

Next, we progress to step three, which focuses on corporate policies and procedures. It's crucial to understand that company standardization plays a pivotal role in keeping all divisions aligned and eliminating unnecessary duplications. This realization has been particularly significant for larger companies over the past 5-10 years, leading them to streamline their operations and avoid redundant efforts across multiple divisions. It's worth noting that some companies skip step three entirely and proceed directly to step four.

Step four: The Regional or the actual site rules. Policies, standards, guidelines, and work instructions. (This is the meat and potatoes of how these programs work. (Breaking it down) for leadership and employees to use the tools. These steps will lead you to the Standard level of Care you provide for all employees. Keep in mind that the ideal image is still the goal you are reaching. (Best-in-class or Benchmark are more accurate terms typically used.) You get closer each year through business planning, targeted improvement initiatives, and allocating the budget, workforce, and resources to achieve the targets for that year's improvements. (see illustration below)

We rarely mention that many programs may ride at the basement level (regulatory requirement). We can all agree that it is not easy to have all programs at a high-performing level and work on all cylinders. You may have safe and even risky programs for your industry or activities. For example, your powered industrial vehicle program may require little work if you have one forklift. However, if you had thirty or more, this size and scope of risk would validate a more robust program with better practices headed toward benchmark. There will be many programs to meet the requirements, and the business will drive where the more significant risks lie with employees and equipment. (does that make sense)? Most companies consider SIF (serious injury and Fatality) risks to drive those activities.

Now, let me swing back to the required training programs. There are initial Training requirements, annual training requirements, and even some three-year training requirements, with periodic Training thrown in here and there. Many companies adopt yearly training requirements for everything. This process is wasteful and costly. It waters your program down and can be redundant and boring, so you are not getting your desired target. Your audience is bored hearing the same ole year in and out.

Let us focus on these training requirements. They may vary by business, but I will establish a general baseline here.

Accident and illness reporting— (required programs for all workers in general and initial and annual retraining). Typically, this component would be in a company orientation, as it is necessary for all employees. The yearly refresher can typically be done via internal communications from leadership to ensure all employees receive the refresher needed.

Bloodborne Pathogens- (required program, for all workers in general, the specifics for qualified workers' initial and annual retraining). Many Companies tell everyone what to do and their responsibility upon finding or seeing blood. Typically, it is also in orientation. (Do not touch it; report it immediately. However, Initial and annual refreshers are required for trained responders. This includes Training on whether the program is updated or changed in any way or if auditing shows deficiencies.

Control of Hazardous Energy- (required program, all workers, in general, the specifics for affected, qualified workers, initial and periodic retraining) initial training for all workers. Then, affected, and qualified Training for individuals working on equipment. This Training can be specific. Covering MSE, situational LO, and complete LO, including stored energy and energy isolation and verification processes. Some businesses may even still have the TAG programs. Training is initial and periodic after that based on the Management of change and audit findings. Remember that this program has some verification activity that must happen annually. Note: special considerations must be made in your training program if you are throwing or rotating disconnects. This would bring in electrical Safety training and PPE into your training program.

Confined Spaces- (required program, all employees in general, then affected workers initial and periodic retraining if rescue assigned annual refreshers) Only applies if you have identified confined spaces on site. However, the depth of this program could be different. Let me explain. You may tell everyone in orientation what confined spaces signs look like and keep out and do not enter. That’s the basic jest in an orientation. However, members must evaluate the spaces and keep the data updated. Members that actively enter spaces must be trained in Confined spaces. This is where I will comment that permit or non-permit needs to be taught. (Oh, I can hear the scoffing as I type). Let me explain my comment if you have a Nonpermitted Confined space. How would an employee know if they were introducing a hazard to the space without proper Training? This is why Training is necessary for every evaluator, entry-person attendant, and supervisor, as well as for self-rescue and professional rescue teams. Training for spaces is in many layers. If you have space, do not tell me; only contractors can enter the space. I will ask how the spaces were evaluated. You may have contractors evaluating spaces. However, I hope you keep trained people on staff to manage the program; someone should have oversight. Confined spaces and initial Training; there is NO annual requirement for Entry attendants and supervisors. However, rescue training is a yearly requirement. Therefore, anyone who is an in house responder would need a rescue refresher annually. You want well-trained members performing a rescue. Now, there is no three-year requirement. However, at some point, your audit program and procedures may change, and this would trigger periodic retraining. Again, it is optional every three years. Some companies choose to do so.

Crane Safety- (required program, affected workers initial and periodic retraining) Initial Training by equipment type classroom (lecture) or a combination of methods and certified hands-on Training. Then, operators are evaluated periodically for any issues, and retraining may be triggered or from program deficiencies.

Electrical Safety- (required program, affected workers' initial and periodic retraining) This Training is necessary for any member working in qualifying electrical situations. Only some employees need this Training. Discuss in orientation, only open electrical panels, or boxes with proper Training. Training is initially required, and there is NO OSHA 3 year requirement. However, the NFPA 70e requires retraining every three years. OSHA does not enforce NFPA 70E. OSHA enforces its standards that relate to electrical hazards. This part could stir some debate. Therefore, there is no 3-year refresher requirement under regulations. The standard refresher requirement would apply here if the standards trained are updated, which typically come from NFPA70e, and these are updated frequently. This requirement would allow you to train every time there is an update. Note: Electrical Safety and Control of Hazardous energy are synonymous with each other.

Emergency Action Plans- (required program, all workers in general, then specifics for affected workers initial and Periodic Training required). Requires all employees to be trained on its basis rather than in its entirety. Many members would need in-depth Training on this plan, including initial Training, but no annual requirement exists. Periodic action is required as members' roles and responsibilities change under the plan. Change points trigger the retraining trigger to update new members and refresh others. General employees need to know where to go and what to do.

Fire prevention program— (required program, all workers in general, then specifics for affected workers' initial and needed periodic Training). Initial Training is typically an orientation format for all employees. It requires periodic refreshers as needed for any changes and updates.

Haz Com program- (required program, all workers in general, then specifics for affected workers initial and needed periodic Training). Typically, this is part of company orientation. However, it is more than that. So, you need design information and Training to cover categories of hazards, such as flammability, carcinogenicity, or specific chemicals. Chemical-specific information must always be available through labels and safety data sheets (SDSs). Then, upon job assignment, the assignments use chemicals, and Training must occur when new chemicals are introduced. There is no annual requirement and no three years either. However, periodic change is when things in your program change.

Hazardous substances— (required program, affected workers initial and annual retraining) Only people affected (users) of products or the location of products shall be trained initially and Annually Thereafter.

Hazardous waste- (required program, affected workers' initial and annual retraining. Hearing conservation- required program, affected workers, and if in HCP, annual refreshers and testing are needed). Initial Training on types of PPE, their ratings, and how to don, doff, and dispose of or clean is required. Annual refreshers are part of the program. Hot work- Welding and cutting are required programs; initial Training is necessary for the affected workers. Inside air quality- (required program, no training required)

Material Handling – (Specialty lifting equipment, truck, train mounted, Derricks, Helicopters) (required program, affected workers initial and needed periodic Training). The basis for retraining is the assessment of operators and the auditing of program deficiencies.

​Powered industrial trucks— (required program, affected workers initial and Periodic Training required). In general, all employees need to understand the rules of the road for their company, such as pedestrian traffic vs. PIV. Then, Training is focused on operators and only requires periodic Training if triggered by deficiencies in the program or incidents occur.

Personal protective equipment- (required program, affected workers initial and Periodic Training required). All workers shall be trained in PPE use and limitations. How to don and doff PPE as well as storage and cleaning.

Process Safety Management- (required program, affected workers initial and Periodic Training required when MOC dictates as well as three-year refresher requirements). Typically, a PSM site would have some general information for all employees at the work site. Then, the Training will be more detailed based on your involvement in the covered process. E.g., general awareness training, competent Training, leadership training, maintenance and engineering, qualified Training, PSM coordinators, and folks who manage the process.

Radiation- (required program if you have ionizing radiation; affected workers' initial and annual Training is required).

Record keeping- (Required program) Requires initial training as a required program however not many employees should be involved in this process.

Respiratory protection- (required program; affected workers' initial and needed annual training). In general, all employees in an orientation must understand the protection rules. Only trained and authorized personnel shall be permitted to wear a respirator. Therefore, additional Training is required for end users initially and annually after that.

In summary, the listing is an all-inclusive and is based on a general sense of the general industry regs. Your specific business could trigger other programs that may be needed based on your conditions).

I listed twenty of the twenty-five required programs. I did not list Specialty topics like Lab Safety, Grain handling, Mechanically Powered presses, LPG gas, and power transmission and generation; there is also an extensive list of Hazardous and Toxic substances that could be broken down fully.

Of these programs, eight have annual retraining requirements—only one, grain handling, requires all employees to be trained. Five have periodic retraining requirements.

My objective here is to get people thinking about what Training they have. What is required? What are you doing with your company's training plan? Waste is waste. Butts in seats is not an effective use of your time now. Look at your situation; wash and repeat training courses must be updated. Adults learn differently today than 10-15 years ago. Your current annual training plan is a wonderful place to start. Look for waste. Look for opportunities to improve the quality and retention of the content. Survey your trainers with students. If the message is not getting through, you may have ineffective trainers. Make the adjustments today and start with a better understanding of what OSHA requires Training, what Training is added by the company, and at what frequencies. Your employees will thank you. I hope I helped get you to think about your safety training program.

​Regards, A Safer Way (because there is always A Safer Way!)