OSHA Training Program Requirements
Within the Occupational Safety & Health Administration’s regulations and subparts, OSHA specifically dictates the requirement for employer safety and health training programs regarding certain hazards. Employers, ask yourself these questions:
- Do you know which specific hazards require a training program?
- Do you know what specific elements comprise a training program?
- Is your current employee safety and health training program designed, developed and evaluated against industry consensus standards and best practices?
- Is your employee safety and health training program defensible?
Outside of their regulations, OSHA has outlined training requirements for General Industry, Maritime, Construction, Agricultural and Federal industries in publication 2254- Training Requirements in OSHA Standards. Its current version is 2015. Just some of the hazard topics in which the OSHA 2254 specifically call out the need for an employer training program include:
- Fall protection
- Noise exposure
- Hazardous Waste Operation & Emergency Response, HAZWOPER
- Powered Industrial Trucks
It is important to note that even certain hazards contained within the OSHA 2254 that do not specify the requirement for a program might also contain specific training criteria to be met, so employers should consult this publication often.
Now let’s look at some common confusion when it comes to defining a training program. And in obtaining some applicable definitions, one of the best industry consensus standards of measure is the ANSI/ASSP Z490.1-2016 Criteria for Accepted Practices in Safety, Health & Environmental Training. First and foremost, a training course or courses differ greatly from a training program. A training course is defined as instructional materials designed to be delivered as a single unit of training. A training program is defined as an established system of managing, developing, delivering, evaluating and documenting safety, health and environmental training. This further speaks to critical program elements such as the roles and responsibilities like training program administrators and trainers along with their qualifications, establishing specific needs assessments and learning objectives, procurement of adequate resources, evaluation, delivery and measurement techniques, and documentation and recordkeeping requirements. These are all critical elements of adult learning principals, known in the industry as ADDIE, meaning Analysis, Design, Development, Implementation and Evaluation.
Simply put, a program goes beyond the content of what is being introduced and delivered, and demonstrates the proactive and reactive moving parts of what makes your safety and health training both ongoing and effective for your workforce. Stating that your employees are trained simply isn’t enough. And this is something that OSHA and other regulatory and legal authorities know well.
Evaluating and developing specific targeted training curriculums, meaning a collection of academic content, is also crucial for meeting learning objectives.
Integrating technology into your workforce safety and health training program, such as online training and other e-learning products, can be highly beneficial and efficient, however, when choosing such training providers, it is equally important to apply the same principals of measure pertaining to the credentials of the subject matter experts behind the e-training content, overall design of the courses and the technology platforms it utilizes. And another valuable standard to assist employers in e-learning technology integration is the ANSI/ASSP-2019, Accepted Practices for E-Learning in Safety, Health and Environmental Training.
In closing, it is also important to mention that many employers require their employees to take an OSHA 10 and/or 30-hour Outreach training course prior to or during their employment. These OSHA 10/30-hour courses have almost become an industry standard, and have been adopted by many state and local agencies and employers alike. However, it is extremely important for employers to be aware that despite their introductory safety and health awareness benefit for employees, these courses do not meet any training requirement in any OSHA standard, which is clearly stated within the OSHA 2254. Employers should never make the mistake of thinking that once an employee has taken either one of these courses that there is no further need for additional safety and health training. Rather, employers should include these courses into their overall safety and health training program as a starting point.
Again, simply stating your employees are trained isn’t enough. Following these training program standards and practices will truly make a difference in your workforce safety and health education, and demonstrate your ongoing commitment as an employer.