OSHA safety training is more than just checking a box

It’s easy to think of safety training as a “one and done” requirement. Take attendance, show a video or two, good to go! Right? Yet, many OSHA standards include explicit safety and health training requirements. Some require “training” or “instruction,” others mandate “adequate” or “effective” training or instruction, and still others call for training “in a manner” or “in language” that’s understandable to employees. What’s more, refresher training or retraining may also be specified in the standards.

Training must cover the hazards employees are exposed to

Think about what hazards your employees are exposed to during normal operations or in foreseeable emergencies — that’s where training comes in: 

• Conduct a workplace walkthrough to observe job tasks and identify hazards to determine what training is needed. 
• Look (and listen!) for hazards such as excessive noise, moving machinery parts, and chemicals. 
• Review the applicable regulations, such as Hazard Communication or Occupational Noise Exposure, to see what elements must be covered in training.

Note that when there’s the potential for a recognized, serious hazard such as extreme heat, heavy lifting, or workplace violence, but no OSHA standard, OSHA can cite the employer under the General Duty Clause (Section 5(a)(1) of the Occupational Safety and Health Act. In that case, you may be able to abate the hazard by training employees in hazard recognition and how to protect themselves. 

Training must include workplace-specific information

Any manner of conducting training is acceptable, including classroom instruction, online modules, videos, and virtual or augmented reality, but trainees also must receive workplace-specific information. For example, if you provide Hazard Communication (HazCom) training for employees exposed to hazardous chemicals, a video will likely cover the basics, such as an explanation of the HazCom standard and how to read labels and safety data sheets (SDSs). However, employees also must understand how HazCom applies to their workplace, including what chemical hazards they’re exposed to, how to protect themselves from those hazards, the details of your written HazCom program, and how to access SDSs in their work areas. 

Training must be understandable to all employees

Employees may have language and/or literacy challenges. OSHA states in a training publication, “If an employee does not speak or comprehend English, instruction must be provided in a language that the employee can understand. Similarly, if the employee’s vocabulary is limited or there is evidence of low literacy among participants, the training must account for this limitation.”

Another key to comprehension and effective training is ensuring employees have the opportunity to ask questions and receive answers when they don’t understand the material. Not all OSHA standards specify that an instructor be present or that a person be available to answer questions immediately. However, employers should review the applicable standard to determine what’s required. A telephone hotline may suffice since employees can get immediate answers with no waiting.

Refresher training and retraining keeps safety top of mind

Many OSHA standards require refresher training and give a frequency. Others may specify that retraining is needed when something in the workplace changes, such as operations, processes, or hazards. Regardless, if you notice employees are failing to follow their training or they have a near miss or incident, that’s an important time to revisit the training elements.

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