Wednesday, September 21, 2011

OSHA Training Requirements: When Training Alone Will Not Suffice

Numerous OSHA standards require the employer to provide training (or instruction, or information . . .) to affected employees on various topics. And in many cases, a simple presentation of the required material (via discussion, video, or PowerPoint presentation) spelled out in the particular OSHA standard may suffice for the employer to comply with the regulation.

For example, the OSHA standard for portable fire extinguisher training (1910.157(g)) requires training for designated users, but it does not specify hands-on practice extinguishing a fire. Now I’m not saying it’s not a good idea to have users discharge a fire extinguisher, I’m just saying it is not specifically required by OSHA.

On the other hand, there are a few OSHA standards where training alone will not cut it! Some OSHA standards go a little further, or in some cases a lot further, and require the employer to conduct some type of practice, evaluation and/or confirmation that the training was understood by affected workers.

Here are a few examples of OSHA training standards that I’m talking about:

  • Respiratory Protection - 1910.134(k)(1) - Training and information. The employer shall ensure that each employee can demonstrate knowledge of at least the following:   (iv) How to inspect, put on and remove, use, and check the seals of the respirator;

  • Permit-required Confined Space Entry –1910.146(k)(1)(iii) - Each member of the rescue service shall practice making permit space rescues at least once every 12 months, by means of simulated rescue operations in which they remove dummies, mannekins <sic>, or actual persons from the actual permit spaces or from representative permit spaces. Representative permit spaces shall, with respect to opening size configuration, and accessibility, simulate the types of permit spaces from which rescue is to be performed.

  • Powered Industrial Trucks - 1910.178(l)(2)(ii) - Training shall consist of a combination of formal instruction (e.g., lecture, discussion, interactive computer learning, video tape, written material), practical training (demonstrations performed by the trainer and practical exercises performed by the trainee), and evaluation of the operator's performance in the workplace.

  • Resistance Welding 1910.255(a)(3) - Personnel. Workmen designated to operate resistance welding equipment shall have been properly instructed and judged competent to operate such equipment.

As you can see, just holding a training session for affected employees is not enough in many cases; the employer is required to go further to confirm the training was effective. The methods that must be employed to meet these additional requirements vary according to which specific OSHA standard you are reading, but include drills, observations, and/or demonstrations of the workers skills.  So remember these additional requirements when you conduct OSHA safety training on these topics, or when you conduct an evaluation of your or a client’s training program.

I’m certain these are the only OSHA regulations with such requirements, just the ones that came to mind as I wrote this article. So I would like to enlist the expertise of my fellow safety professionals and ask them to share their knowledge with others, by posting in the comment section below, any OSHA standard they can think of that has a similar requirement. I also invite other comments about this topic, so please share them with our readers. 

And last but not least, please pass a link to this blog post along to others in your network who you think may benefit from this information.

1 comment:

  1. OSHA issued a 2002 fact sheet that states hands-on training on fire extinguishers is a requirement for those employees who are expected to use them. Available at: (last accessed 6/14/2013).


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