Why OSHA Training?
Many of the OSHA regulations have specific requirements on training for fall protection, hazard communication, hazardous waste, asbestos and lead abatement, scaffolding, etc. It seems relatively safe to say that OSHA expects workers to have training on general safety and health provisions and hazard recognition, as well as task-specific training. Training workers regarding safety and health is one of the most effective accident prevention techniques.
Many standards promulgated by OSHA explicitly require the employer to train employees in the safety and health aspects of their jobs. Other OSHA standards make it the employer's responsibility to limit certain job assignments to employees who are "certified," "competent," or "qualified"—meaning that they have had special previous training, in or out of the workplace. The term designated personnel means selected or assigned by the employer or the employer's representative as being qualified to perform specific duties. These requirements reflect OSHA's belief that training is an essential part of every employer's safety and health program for protecting workers from injuries and illnesses.
As an example of the trend in OSHA's safety and health training requirements, the Process Safety Management of Highly Hazardous Chemicals standard (29 CFR 1910.119) contains several training requirements. This standard was promulgated under the requirements of the Clean Air Act Amendments of 1990. The Process Safety Management standard requires the employer to evaluate or verify that employees comprehend the training given to them. This means that the training to be given must have established goals and objectives regarding what are to be accomplished. Subsequent to the training, an evaluation would be conducted to verify that the employees understood the subjects presented or acquired the desired skills or knowledge. If the established goals and objectives of the training program were not achieved as expected, the employer then would revise the training program to make it more effective or conduct further sequent refresher training, or some combination of these. The requirements of the Process Safety Management standard follow the concepts embodied in the OSHA training guideline.
The length and complexity of OSHA standards may make it difficult to find all the regulations for training. To help employers, safety and health professionals, training directors, and others with a need to know, OSHA's training-related requirements are found in Training Requirements in OSHA Standards and Training Guidelines (OSHA 2254). For more detail, consult the Code of Federal Regulations.
It is usually a good idea for the employer to keep a record of all safety and health training. Records can provide evidence of the employer's good faith and compliance with OSHA standards. Documentation can also supply an answer to one of the first questions an accident investigator will ask: "Was the injured employee trained to do the job?"
Training in the proper performance of a job is time and money well spent, and the employer might regard it as an investment rather than an expense. An effective program of safety and health training for workers can result in fewer injuries and illnesses, better morale, and lower insurance premiums, among other benefits.