Setting Up OSHA-Mandated Training

How many types of OSHA-mandated training must an employer provide to employees? It depends on the nature of the company.

Yet the requirements for training reach companies of all sizes and in all industries. Every owner, even an owner/operator with no employees, should have for reference “Training Requirements in OSHA Standards.” (See the 270-page document via https://www.osha.gov/sites/default/files/publications/osha2254.pdf.)

Every one of the training expectations established by OSHA derives from implementation of the Occupational Safety and Health Act of 1970. As industrial practices and tools change, requirements are added and modified. The basic objective of OSHA, however, “to assure safe and healthful working conditions…,” remains constant.

The 270-page document itself is not a standard or regulation. It is a consolidated reference of descriptions of mandatory safety procedures and standards.

The best place for a business owner to start when determining which standards apply to his or her company is the state office for OSHA in the state (or states) in which the business operates. Each state has an OSHA-approved plan.

Professional organizations are a good source of information about niche-specific training required. Moreover, professional organizations such as CETA, PWNA, UAMCC, and WJTA can recommend training courses and trainers.

OSHA trainers—or those who have met the criteria to go out and deliver job-related safety and health training to workers, supervisors, and employers—belong to a specially designated category. OSHA trainers, a very specific designation, are qualified by an OTI.

An OTI [OSHA Training Institute] is a nonprofit organization that has been authorized by OSHA to deliver training to workers, supervisors, and employers. The mechanism for designation of OTIs includes several variables, including the assurance there is sufficient regional dispersion of trainers as well as sufficient representation of languages other than English.

OSHA maintains a list of OTIs at its website (OSHA.gov). The list is not comprehensive. OTIs will also carry the designation at their websites. Prospective students looking for a specific class will be able to ask for and see the class leader’s authorized trainer card (with effective dates) and the name of the ATO [Authorized Training Organization] to which the trainer belongs.

The short of it is that if OSHA mandates training in a particular area, someone at a company—the safety officer, the employer, etc.—will take initial training from an authorized trainer who carries that designation. For some types of training, all employees may be required to receive their training from an OTI trainer.

Again, ascertaining that a company meets all requirements for training employees begins in consultation with state OSHA. Readers who are owners of businesses will in almost all instances have interacted with OSHA-authorized trainers. The authorized trainers provide a significant number of classes in general industry and in construction (10- and 30- hour courses for each).

Many individuals who are authorized trainers have their information listed in a database at the OSHA website, but not all such trainers do because the listing is compiled from trainers who must request inclusion. Some trainers wish to have their contact information kept private.

Perspective

Some members of our industry have had the opportunity to be involved in OSHA training in more than one way and more than one discipline. When Linda Chambers, the brand and sales manager for GCE/Soap Warehouse Brand in Norcross, GA, worked in veterinary medicine, she worked as a trainer.

In her current position, Chambers also has a training role. “I do all the employee training in house by following the OSHA guidelines on how to set up and run training,” she explains.

Chambers reminds us of an essential point. It is that OSHA is not trying to add to the cost of doing business. Instead, it is trying to keep employees safe and healthy, which reduces costs. To that end, it provides a wealth of training resources at no cost.

“I believe for a small business there is no need to spend large amounts of money on premade programs when OSHA gives you all that you need and how to do it for free,” says Chambers. (Outreach trainers themselves also have access to training resources from OSHA.)

There are two challenges for the business owner when developing a program for ongoing, mandated OSHA training. The first, already mentioned, is verifying the training required. The second is deciding how to provide it.

The mechanism of having a point person who receives training from an authorized trainer initially is one method of staying in line with regulations. Another is to hire a consultant to help with the setup of in-house mandated training.

“As I stated before, I think that a small cleaning company can set up their own [training] and not have to shell out big money to run a program for their employees,” says Chambers. “But once you get to a certain size, even more than 10, you could see the benefits of using at least an online program that could be more cost-effective than doing it yourself.”

Experience with methods of training will dictate future choices. Perhaps as the company grows, the owner may not have sufficient time to do all these things. “And then if the owner just doesn’t have the desire to do the work, by all means go ahead and look into paying for a onetime or ongoing OSHA training program,” says Chambers.

The logistics of setting up in-house training programs does take time. It also requires attention to detail.

The first training program Chambers set up was when she ran veterinary clinics.

“Once I came to [my current position], I set up the basic 10 hours of training needed for all entry employees and then added additional training for employees in specific jobs that required it,” she explains.

One constant for the in-house person charged with liaising with OSHA is figuring out which employees require which training. It must be figured out correctly.

“For instance, everyone needs GHS [globally harmonized system] labeling and SDSs [safety data sheets],” explains Chambers, “but not everyone needs defensive driving or forklift training.”

Making the most of the combination of training that must be obtained from an authorized trainer, training materials obtained from OSHA, and experience is key. Moreover, paying a fee for training sometimes is the best option.

“Now we do pay for some parts of training, like the defensive driving,” says Chambers. “I first read all I could on the [OSHA] website and watched their free training videos. Then I followed their guidelines and created our 10-hour program, creating the tests and tasks like watching videos and hands-on demos.”

The involvement Chambers has had with OSHA training sessions over the years has led to doing consultation. “I do give a class on how to learn to create and run your own OSHA training for business.”

Which Training?

As the 270-page OSHA reference cited in the first section indicates, types of training potentially required by 29 CFR 1910 are extensive. Some parts seem easy enough to sort out, such as the elements of the subpart D (walking-working surfaces) involving ladders (1910.23).

But things can get complicated quickly. What about 1910.134? It’s the standard that applies to respirators. It’s not just about when employees must wear respirators, but also how the respirators must be fitted and the employee medically evaluated.

Employees required to wear respirators must be properly fitted and medically evaluated to assure they can tolerate the device—two protocols in the OSHA standard for respiratory protection (1910.134 in 29 CFR). Respirators also must be properly cleaned and stored.

General industry standards that may apply to manufacturers, distributors, or contractors in our industry include exit routes and emergency planning. Does the workplace have an emergency action plan (1910.38) and a fire prevention plan (1930.39), for instance?

No doubt every company does have the required action plans. But is the documentation about the training that workers received in place?

Training requirements under the general industry 29 CFR 1910 include everything from noise exposure (1910.95) to bloodborne pathogens (1910.1030). Training in hazardous materials falls under more than one standard (e.g., 1910.120 hazardous waste operations and emergency response, 1910.1200 hazard communication).

And what about the power washing contractor who begins cleaning a permit-required confined space without proper training in standard 1910.146? Without training in confined spaces, the contractor may not be able to readily sort through which is a permit-required space and as such could erroneously rely on information from the owner of the confined space.

The challenge for developing OSHA-mandated training is in doing all the training that’s necessary. Obviously, on the employee side of things, a just-this-once mindset must never be an event. For example, an employee who has not been trained in powered industrial trucks must never operate one.

A just-this-once mindset can get an employer into a great deal of trouble. It’s imperative to identify standards that apply to a workplace and then provide the OSHA-sanctioned training in each one of them.

And document the how, when, who, and what of all training completed.