Our compliance experts regularly get questions on OSHA training provisions, so we’re providing answers to some of the most common questions here.
In most cases, OSHA does not require specific training courses for the instructor. Rather, the regulations describe the knowledge the trainer must possess, which is typically gained through education, experience, or a combination of both. For example:
Knowledge and experience alone does not make a good trainer, however. The instructor must be able to convey information effectively, in an engaging manner, and be able to answer questions from trainees. Instructors may benefit from training on how develop and present material, how to understand audiences, and how to appeal to different learning styles.
A lot of regulations require training, and others imply a need for training. For instance, Emergency Action Plans under 1910.38 requires employers to develop “procedures to be followed by employees” although the word “training” doesn’t appear in that section.
The training each employer must provide depends on its operations. If employees use hazardous chemicals, they probably need hazard communication training. Each employer must determine which regulations apply, then determine if the regulation requires training.
Quite a few regulations require annual training. Among them are Occupational Noise Exposure, HAZWOPER, Respiratory Protection, Fire Brigades, Portable Fire Extinguishers, and Bloodborne Pathogens (but there are others).
In addition, some standards require evaluations, like three-year evaluations of powered industrial truck operators. Some regulations don’t specifically mention refresher training, but do require reviews, such as periodic inspections under lockout tagout. Even where refresher isn’t required, providing it may be a good idea. If employees do not retain information and cannot answer questions about the training they received (possibly several years ago), your company could be cited for failure to provide training.
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