Complying with OSHA Training Standards with a Training Matrix Approach

No matter what industry you are in, Construction, Maritime, or General Industry, Federal and State OSHA require training for your employees on numerous programs and topics.

Some companies take the “one size fits all” approach and train everybody on everything. But there are serious problems with this approach.

The crucial question my clients ask is “How do I know what training is required for each employee and how do I keep track of training completion and retraining frequency?”

The best management practice in this area is to design a system that determines what hazards are present in the workplace, which training topics are required for specific groups of employees (and some go beyond the OSHA standards), and how often to give training. A training matrix is an excellent ally for your training management needs.

Why Training Management is as Important as Training Itself

First, training is expensive, whether you count dollars, time spent, or the cost of taking people away from their work to sit in a classroom or in front of a screen. People also really don’t like spending time on topics that don’t directly relate to their jobs or provide some benefit to them.

For example, if you require administrative employees to take Lockout-Tagout training, chances are you will get a 0% return on the money and time invested, as well as totally irritating every single office worker!

Another complication is when initial training should be given and how often refresher classes are required?

Again, some companies will offer the full gamut of safety training classes during new employee orientation and refresher training on an annual basis. However, not every topic is required to be revisited that often.

Now, for high hazard operations such as electrical contractors or warehouse operations, holding electrical safety refresher or forklift operator training annually may make good sense. But OSHA requires these classes on a minimum 3-year calendar. Even though an employer can always exceed OSHA requirements, it’s not always the most efficient or effective way to train your employees. 

It seems counterintuitive, but forklift drivers who operate their PITs frequently, like in a warehouse environment, are proficient enough not to need annual training (assuming they are operating safely and following the rules!). It’s the occasional drivers, people who only get on a forklift once in a while, who get the most benefit from a hands-on refresher like having a “forklift rodeo” every year!

Got OSHA Training Requirements? Use a Training Matrix to Manage Compliance

It’s important to understand that safety training is a component of an overall safety management system (SMS). Managing training is just as important as OSHA recordkeeping and reporting. It also requires its own dedicated training management system (TMS). To treat safety training as a “stand-alone” topic and not integrate it into your SMS is a huge mistake.

Below is an example of a training matrix for a hypothetical company with operations in California.

The first column lists the title of the training requirement. Next comes:

  • the standard related to the requirement
  • which employees are required to take the training
  • length of the class
  • re-training frequency
Training matrix example for OSHA training

This is a good place to start when you’re first setting up your TMS. It helps you make the case to management that certain training is required by OSHA, so the time and resources aren’t a “nice to have” but a “must-do”!

This type of matrix can be expanded in many ways, such as by adding:

  • job descriptions or individual workers to show which topics are required for each type of employee
  • assignment and completion dates
  • training resources (internal, contractor, CBT, etc.) who will provide the classes

Smaller companies can manage training using the spreadsheet approach. But for multiple locations, large numbers of employees, or very diverse work activities, an integrated TMS software program will be required. As mentioned above, some SMS programs have TMS modules either included or available as add-ons to integrate all of the administrative requirements for managing safety with the training element.


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Technician training matrix example for an organization

Better Safety Management Starts with a Training Matrix

So, to start managing safety training better at your company (or if you are new to the EHS management job!), we recommend you start with a hazard analysis to determine which training topics are required for all of the different tasks and/or job descriptions at your workplace. Then, use the training matrix approach to organize this information into a form that allows you to manage and track when the training is taken by each individual and when retraining (if any) is due.

Obviously, the matrix is only as good as the information you put into it. A matrix quickly becomes useless if out-of-date. Other documentation such as signed class rosters (sign-in sheets); copies of the course information offered, quizzes and tests, and instructor information should all be retained to both prove to any regulators that training really was provided and the training had value. These records also help you keep the matrix up to date since training names and completion dates can easily be transferred to the spreadsheet or TMS software.

To find lists of training topics required by OSHA, check the federal OSHA and your State OSHA plan (if applicable) websites. Safesite also has resources for you to make sure your company is giving the right training to the right workers at the right time!

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Dave Paoletta

By Dave Paoletta

David Paoletta, MS, MBA, CSP, CUSP, is a research analyst and subject matter expert for Safesite, a safety management software company based in San Francisco, CA. He is also a principal consultant with New Dimensions in Safety in Alameda, CA. David has extensive utility field safety experience with PG&E and PNM New Mexico. He is a Past NM ASSE SPY Award winner and a Past President of the San Francisco Chapter ASSE.

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