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November 26, 2007
Do I Need to Document Training for OSHA?

Which OSHA standards require training documentation? The fact is that while many OSHA standards require employee training, most do not require that you document that training. But, some do. Some key general industry standards that require you to document (or "certify," as OSHA usually says) that training has been conducted include:

  • Process Safety Management, 29 CFR 1910.119(g)(3)
  • Hazardous Waste Operations (HAZWOPER), 29 CFR 1910.120(p)(8)(iii)(C)
  • Personal Protective Equipment, 29 CFR 1910.132(f)(4)
  • Respiratory Protection, 29 CFR 1910.134(m), which does not specifically use the word "training," but refers to "written information regarding medical evaluations, fit testing, and the respirator program."
  • Permit-Required Confined Spaces, 29 CFR 1910.146(g)(4)
  • Lockout/Tagout, 29 CFR 1910.147(c)(7)(iv)
  • Powered Industrial Trucks, 29 CFR 1910.178(l)(6)

Similar standards for the construction industry also require documentation of training.

What do you have to document? Most of the training documentation requirements are pretty much the same from standard to standard. Here are a few examples:

  • PPE training: "The employer shall verify that each affected employee has received and understood the required training through a written certification that contains the name of each employee trained, the date(s) of training, and that identifies the subject of the certification."
  • HAZWOPER training: "The employer shall certify that each covered employee has attended and successfully completed the training required in paragraph (p)(8)(iii) of this section, or shall certify the employee's competency at least yearly. The method used to demonstrate competency for certification of training shall be recorded and maintained by the employer."
  • Why It Matters ...
  • Failure to document employee safety training when required by OSHA can lead to citations and fines.
  • Even when documentation is not required, keeping good records of safety training helps you assess future training needs and keep track of employee progression through training programs.
  • Forklift training: "The employer shall certify that each operator has been trained and evaluated as required by this paragraph (l). The certification shall include the name of the operator, the date of the training, the date of the evaluation, and the identity of the person(s) performing the training or evaluation."

The wording differs a little from standard to standard, but the required information is basically the same:

  • Name of the employee (signature is not required, but is OK with OSHA, if that's what you want to do)
  • Name and signature of the trainer
  • Date of training
  • Subject of training
  • Proof of competency (results of some kind of evaluation, such as a test or demonstration of ability) and date of evaluation

Documentation must be written and filed. If you use computer-assisted training programs, you can take advantage of learning management systems (LMS) that allow you to track and document employee training and evaluations. Whatever documentation system you use, however, you have to be able to produce your safety training records on demand any time OSHA wants to take a look. Which raises the question of how long you should keep training records. You should certainly keep training records on each employee for as long as that person is employed by your organization. Beyond that, it's wise to hang on to training records for a few more years in case the employee is reemployed, for example, following a layoff.

Should you document training even if OSHA doesn't require it? The best policy is to document all formal safety training for each of your employees. You can also document additional information not required by OSHA. For example, it might be useful to keep track of the following safety training data:

  • Past training on the same safety topic
  • Next scheduled training date
  • Summary of training content (objectives, key training points)
  • Reason for nonscheduled retraining (for example, an accident or deterioration in safety performance)
  • Safety orientation dates for new employees and orientation program content
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