This article is about documenting OSHA training. The way we do it at Compliance Plus is one way. It is not the only way. Let me start with two questions. Please answer them in your mind before you proceed to the next paragraph. “Assuming you do document employee training, why are you doing it? What purpose does it serve?”
Did you answer that you do it because OSHA requires it? That would be wrong in most cases. Did you answer that you do it so that you can keep up with it? That’s a good answer, but wouldn’t it be better if you did your recordkeeping in a way that helped satisfy OSHA requirements. Better yet, why not do it in a way that also protects the employer?
OSHA’s formaldehyde standard requires new and annual employee training. Also, training when things change. Three years ago, formaldehyde was reclassified as a carcinogen. This year the language on a formaldehyde warning will change. Yet, with all this, OSHA has no requirement that employers document formaldehyde training. However, they do require that any training records you generate be retained for three years. Does Compliance Plus document formaldehyde training? Yes, because those records protect an employer from an employee claiming they were never trained.
In states where federal OSHA applies, the hazard communication standard is another standard that does not require training documentation. Here, we train new employees and provide an annual refresher courses for all. We also train when there are changes in the standard as happened in 2013 to 2016. This is when OSHA introduced the Global Harmonization System (GHS) that featured a new labeling system and phased out MSDS files for SDS files. In some cases, state OSHA programs require annual training and inventory reporting.
The Bloodborne Pathogen Standard requires detailed documentation. There are thirteen distinct areas that must be covered in initial training and almost as many in annual training. Here, if you are using a vanilla sign in sheet, OSHA could rule it inadequate. Other topics include safe sharps, free hepatitis B vaccination, and infectious diseases like the Ebola virus.
Training employees to operate fire extinguishers is distinct. The employee must, prior to being approved, discharge or observe an actual discharge of a fire extinguisher.
What about general industry training? Just so you know OSHA considers formaldehyde, hazard communications and bloodborne pathogens as general industry topics. However, I was referring to subjects like slip, trip, and fall safety, ladder safety, lifting safety, office worker safety, and a few more. We have 25 PowerPoint training presentations on the most widely used general industry topics. If you do that type of training, do you document it? You should. Sign in sheets are sufficient for this training. Do you dispose of this certification in three years? You should not. Keep it permanently. It will come in handy if you have an employee injured from a ladder fall or from other workplace hazards. Be sure to update the training when there are changes within a standard.
Emergency action, employee actions to take during an emergency, and safe areas located within the facility are also areas that should be given to every employee.
General provisions require the employer to make a hazard assessment, to train employees in how to use personal protective equipment, and in most instances, to pay for that equipment.
There is a lot more but we simply don’t have the space to cover it. You can access every standard on the internet. For example, type in “Formaldehyde Standard,” and then search for training requirements. Recordkeeping requirements are another section to review. Find out if you are training the right employees. It is not a good idea to train the entire workforce on hazards in which only a few are exposed.
What about using the OSHA volunteer program? In my opinion, that is a bad idea. There are too many cases in the funeral industry where this backfired. OSHA is complicated enough. We should avoid doing things that make it more complicated. Follow the Keep It Simple Stupid (KISS) concept.
Have a question? Email me, Gary Finch at gfinch@kisscompliance.net.