Identifying a need for refresher training

A lot of OSHA regulations require training, but relatively few require annual refresher training. However, if employees don’t remember the information delivered in training, they probably need refresher training.

If an OSHA inspector shows up and questions your employees, but your workers cannot answer those questions, your company can be cited for lack of training, even if you offer a piece of paper showing that the employee attended training. For training to be effective, employees must remember what they learned.

Often, new hires receive training, but might work for many years without a refresher. If employees attended training many years ago, refresher training may be helpful. For example, if an employee attended hazard communication upon hire, but never needed to retrieve a Safety Data Sheet for the last ten years, does that person still remember how to find one?

To determine if refresher training might be needed, ask employees specific questions about key topics they should have learned. You don’t have to ask every worker, and you don’t need a long list of questions. Just spot check a few workers with a few key questions. If they can’t answer those questions, more training is probably needed.

Another good way to identify a need for refresher training is to audit the workplace. If you find hazards or unsafe practices that were mentioned during previous training, that’s an indication that employees may need some refresher training.

Limited refresher

If you provide refresher training when a regulation doesn’t require it, you don’t have to go through an entire program. You can keep the sessions brief and just touch on key points. In fact, you might cover different points each year to help keep the content fresh, rather than doing the same program every year.

In some cases, refresher training is required on an “as needed” basis. For example, if a forklift operator is involved in an accident, OSHA requires refresher training per 1910.178(l)(4). This regulation requires training only “in relevant topics” so you don’t have to repeat a full program. As an example, if the operator was carrying an unstable load, training might focus on how to recognize an unstable load and how to secure it.

If that refresher is required, be sure to document that it was provided. Your company probably documented the accident, but if you don’t have documentation that refresher training was provided, and if an OSHA inspector finds a discrepancy, your company could be cited for failure to provide the refresher training.