Tools to navigate the maze of OSHA training requirements

With nearly 1,000 different OSHA standards and hundreds of related training requirements, it's daunting to determine what applies to your workplace. Each regulation is unique as to when, how often, and what training and documentation must occur. Some requirements are very specific and others ambiguous, leaving it to the employer to determine appropriate training scenarios. Some have requirements for retraining in a certain period or when there's a new hazard or new equipment, a change in the worker's responsibilities, inadequacies in knowledge, an incident, and so on. OSHA expects employers to tailor training to their company and industry and recognize any hazard, machinery, operation, or situation that warrants training or retraining to ensure safety.

A recent webinar, OSHA Safety Training Assessment, by HSI, a provider of environmental, health and safety, compliance, and professional development training solutions, provided helpful insights into navigating the OSHA website as well as presented a free safety training assessment tool to help employers identify training requirements.

OSHA website

There are two ways to look for training requirements on the federal OSHA website:

1. Handbook 2254: Training Requirements in OSHA Standards. This 270-page booklet provides an overview of training requirements by standards. It's a good starting point, but it's not updated as often as the standards, so it's important to also go to the individual standard.
2. Go to the individual regulation. OSHA standards fall into four categories, agriculture (1928), construction (1926), maritime (1915,1917,1918), and general industries (1910). To search for the regulations, use this format:https://www.osha.gov/laws-regs/regulations/standardnumber/xxxx/xxxx. For example, PPE for general industries would be https://www.osha.gov/laws-regs/regulations/standardnumber/1910/1910.132 .

In addition to the regulations, Letters of Interpretations clarify OSHA requirements and how they apply to particular circumstances. To find specific details, use terms such as "forklift training" in the keyword search.

Importantly, employers in State Plans, need to comply with both federal and state requirements. To determine what unique standards apply, visit https://www.osha.gov/stateplans/, select the state from the map, and open the plan details. The sections, State Plan Standards and Regulations and Unique State Plan Standards, identify the differences in the state.

OSHA Safety Training Assessment Tool

HSI offers a free tool to help employers identify which regulations apply to their workplace. It takes 15 - 20 minutes and involves answering a series of easy-to-understand questions online, which will then produce an individualized report. For companies with several worksites, the assessment can be repeated multiple times. For a sample of the questions and report.

The tool can assist employers to develop training programs, identify gaps in existing plans, and stay up to date with evolving standards.

Common misconceptions about OSHA training

• Complying with federal OSHA is all that is required. Federal OSHA is the minimum for all states. States can add requirements, including state-plan states. There are also other sources of training mandates. Additional training requirements may appear in other standards (i.e. NFPA, ANSI) and are adopted by reference and are mandatory.
• OSHA 10-30 replaces OSHA training. The OSHA Outreach Training Program provides workers with basic and more advanced training about common safety and health hazards on the job. However, it does not replace the training requirements of the individual regulations.
• Training only has to be provided if the words "must" or "shall" are used. While "must" and "shall" do indicate a mandate to provide training, other wording can imply a need for training and employers have been cited for failing to deliver training when they should have recognized it was necessary. Be cognizant of words such as "instruct," "inspect," "handled in a manner," and so on. While the word "should" is not a mandate, it is a best practice.
• Distributing and signing a written plan constitutes training. While a review and discussion of the written plan should be an integral part of training, it is not sufficient training.
• Online training meets the requirements for training. In a Letter of Interpretation, the agency writes, "...the use of online training by itself would not be sufficient to satisfy OSHA training requirements unless that training contains interactive and hands-on components. To be effective, training must result in mastery of the training material (such as, for example, safe work practices or the safe and appropriate use of tools and personal protective equipment). Online training without interactive and hands-on components would not meet this goal."
• Training does not have to be provided in different languages. In a Letter of Interpretation, OSHA has made it clear that an employer must instruct its employees using both a language and vocabulary that the employees can understand.
• Refresher training does not have to be provided unless specified in the regulation. Remember, if during an inspection employees cannot answer questions from the Compliance Officer, the company can be cited for lack of training, even if there is documentation of training. It may not be necessary to repeat full training, but refresher training when there is a new exposure, incident, near miss, infrequent use by the worker, or supervisor concern is important. Be sure to document refresher training.

An advisory document provides more information on the development and delivery of training.