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Clarifying OSHA’s Annual Training Requirements

Originally posted December 20, 2014 by Chris Kilbourne on http://safetydailyadvisor.blr.com

“Wherever OSHA standards require that employee training be conducted ‘at least annually,’ OSHA interprets that to mean that employees must be provided retraining at least once every 12 months (i.e., within a time period not exceeding 365 days),” says David Galt, Managing Editor—Safety, with Business & Legal Resources, Inc.® (www.blr.com).

This annual training need not be performed on the exact anniversary date of the preceding training but should be provided on a date reasonably close to the anniversary date, taking into consideration the company’s and the employees’ convenience in scheduling, he explains.

If the annual training cannot be completed by the anniversary date, the employer should maintain a record indicating why the training has been delayed and when the training will be provided.

“Keep in mind that the term ‘at least annually’ is generally regarded as indicating that circumstances that warrant more frequent training may occur,” Galt says. “It is extremely important that employees are trained to protect themselves from all known workplace hazards, including new hazards which may result from changes in workplace practices, procedures, or tasks.”

For example, OSHA’s bloodborne pathogens standard at 29 CFR 1910.1030(g)(2)(v) provides for “additional training when changes such as modification of tasks or procedures or institution of new tasks or procedures affect the employee’s occupational exposure.”

More frequent training may also be required when employee performance suggests that the prior training was incomplete or not fully understood. OSHA training requirements typically include the following:

  • Hazards of the work assignment;
  • Safe performance of the operation and proper use of any required personal protective equipment (PPE);
  • Basic OSHA regulations on the operation; and
  • Application of training to the particular worksite and the equipment being used.

(Sources: OSHA Letter of Interpretation dated 1/24/07 and BLR’s Special Report:Teaching OSHA Requirements to a Diverse Workforce)

Why It Matters

  • Training and proof of training are critical defenses against OSHA inspections.
  • Training is more than a onetime event; it needs to be ongoing as necessary.
  • Keeping your employees up-to-date on all the training they need will help prevent accidents and keep everyone safe on the job.