Monday, January 2, 2012

Comprehensive Lists of OSHA Training Requirements Now Available - Perfect Tool for Planning and Audits

Have you ever visited the OSHA website and looked at their sizable selection of OSHA publications available to view and download? Some of them are excellent publications, some are so-so. But over the years, the one that I got the most use out of (by far) was titled “Training Requirements in OSHA Standards and Training Guidelines”, issued in 1998. As the name implies, the publication lists excerpts from the OSHA regulations where employee training is required. Unfortunately, the document is 14 years old now, and I suspected it was out of date. 
I started looking harder at the document last fall, and realized just how outdated it had become. There have been a few new OSHA standards issued since 1998 that require employee training. Quite a few OSHA standards that required training have been revised since then, too, and even a couple of them deleted. Being a little bit OCD (really), I decided to keep digging and create my own, updated list of OSHA standards that reference training; I nearly bit off more than I could chew.

I poured through the current OSHA regulations for general industry and construction (I’m still trying to decide if I should try and tackle maritime) to find all the references to employee “training” that I could. I also looked for OSHA standards that require the employer to “inform employees”, “make sure employees are knowledgeable about”, use a “certified” worker, designate “competent persons” or “qualified persons”, and similar verbiage that implies some level of employee training. After a few months of research, I had compiled over 250 pages of information, quite a bit more than appeared in the original OSHA document.  I decided this information was too valuable to keep to myself, so I published the results on our brand new website, - (yes, I finally got the darn website finished).

You may be quite surprised (as I was) how many obscure references to OSHA training are buried in the OSHA regulations. As a result, my future OSHA training audits will be more comprehensive. There are also some surprising irregularities in OSHA training requirements. For example, the section of the OSHA regulations with the most references to employee training (by far) are the standards for cranes and derricks used in construction;  the section with the fewest references to training (only one) are the standards for cranes in general industry.  It also struck me as scary how many sections of the OSHA regulations have absolutely no reference what-so-ever about employee training!

Keep in mind this was a non-exhaustive review of the OSHA standards, meaning there could be something I overlooked that did not get listed. So please use this information as it was intended, as a guideline to help you home in on areas that require training, while keeping in mind that due diligence requires you to always reference the official OSHA CFR to make certain you have everything covered. And if any of you Safety Pros out there see a particular OSHA training regulation I overlooked and are kind enough to let me know, I will update the website where required.

Here are the links to the OSHA training requirements for General Industry, and the OSHA training requirements for Construction. It is my hope that my fellow safety professionals and all the employers who are regulated by OSHA find this information as useful for planning and audits as I have.

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