Common questions on OSHA training requirements

Our compliance experts regularly get questions on OSHA training provisions, so we’re providing answers to some of the most common questions here.

What courses or certifications do I need in order to provide training on (some topic)?

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:

• The powered industrial truck regulation at 1910.178 says that training “shall be conducted by persons who have the knowledge, training, and experience to train powered industrial truck operators and evaluate their competence.” OSHA clarified that the instructor must have experience with the equipment (truck type) or attachment in order to provide training.
• The bloodborne pathogen standard at 1910.1030 says the trainer “shall be knowledgeable in the subject matter covered by the elements contained in the training program as it relates to the workplace that the training will address.” OSHA clarified that the trainer need not be a health care professional, but if there are deficiencies in the quality of the training, OSHA may question the trainer’s background.

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.

Which regulations require training? What training are we required to provide?

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.

Which regulations require annual refresher 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.