OSHA Training Documentation and Instruction Requirements
In addition to OSHA’s specific training standards, the agency evaluates companies against overarching standards for training documentation and delivery.
These include storing records of training coursework and attendance for three years, unless otherwise specified, and delivering training by competent instructors in a manner employees understand.
What’s the Best Way to Document Training?
Many OSHA standards stipulate that training must be documented and stored for a period of time. And if you are inspected by OSHA, one of the first things they’ll request is your training records.
Companies may choose to document training in paper files, digital records, or both.
Paper records are inexpensive but must be properly stored and organized so that they are easy to locate when needed.
Digital records allow easy, consistent updates across teams, and, if the software has an export function, can easily be transferred to PDF files for printing.
Whichever format you choose, be sure your employees can understand and use your documentation system with ease.
A good training documentation system includes:
- A process for recording the name of the employee (a signature is not required), the trainer (with signature), training materials or a description of the topics covered, and the date of each training session.
- Proof of competency and an associated date. Proof can be the results of an evaluation or a demonstration of ability. (This only applies to certain tasks under OSHA law, but can be useful to have for every task if you are inspected by OSHA.)
- A way to verify the appropriate records have been created and stored.
- A record storage policy that includes how and when to destroy records when they are no longer needed.
- Record backups.
How Long Should I Store Safety Training and Meeting Minutes?
Where OSHA doesn’t specify a length of storage overall, it does require a certain length for specific tasks. Generally, it’s best practice to hold onto safety training records (curriculum and attendance) for the length of employment.
What is the OSHA Definition of Qualified vs. Competent Person?
Some OSHA standards stipulate that a competent person must manage training, while others reference a qualified person. The definitions of these and other terms related to trainer qualifications can be found within OSHA 29 CFR 1926.32.
A competent person is “capable of identifying existing and predictable hazards in the surroundings or working conditions which are unsanitary, hazardous, or dangerous to employees, and who has authorization to take prompt corrective measures to eliminate them.”
A qualified person is just a competent person with a specific, verifiable certification or professional standing.
With regard to training, it is important to choose persons that are competent based on capability. This may or may not be dependent upon prior coursework or even certifications. When selecting a competent person, ensure that:
- The trainer is knowledgeable and capable with regard to the topic.
- The trainer is capable of training others.
OSHA 29 CFR 1926.32(m) states that a qualified person is someone “who, by possession of a recognized degree, certificate or professional standing, or who by extensive knowledge, training, and experience, has successfully demonstrated his ability to solve or resolve problems relating to the subject matter, the work, or the project.”
Employers are responsible for ensuring the competent and qualified persons they select for on-the-job training are trained and/or certified (CFR 1926.1430, 1915.7).
What Does OSHA Mean By “In a Manner Employees Understand?”
Many OSHA training standards say that training must be provided “in a manner that employees understand.” OSHA says this statement means, first and foremost, that training must be delivered in the language, vocabulary, and format an employee can best understand.
Simply having a Spanish-speaker translate from English during a safety class may not be sufficient for learners to understand. Try to locate a safety professional who is fluent in the language and experienced in providing effective bi-lingual training. (Some training companies specialize in this area.)
Because OSHA stipulates employees must understand training such that they can apply it, OSHA compliance officers will review training documentation and observe employees’ demonstration of safety skills.
Therefore, if training is completed in an employee’s first language but she is still unable to perform her tasks safely, then additional training may be required by law.
Other requirements found within the standards state that understanding must be verified (and documented) before work can begin. Lockout/Tagout (1910.147c) requires employers to verify that the employees have acquired the knowledge and skills which they have been trained through observation.
Spanish Safety Training Resources
In addition to their Spanish language Outreach Program, OSHA lists Spanish safety training resources on their website.
Helpful Spanish training resources include:
The free Safesite app is available in Spanish, including features like safety meetings, inspections, and incident reports.
Portuguese Safety Training Resources
OSHA has a number of safety training resources in Portuguese, and the Brazilian Worker Center offers some training in partnership with OSHA.
The Safesite app can be set to Portuguese or French, so that workers can run safety meetings, inspections, and incident reports in their primary language.
Visit OSHA’s website to search for training resources in other languages.
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