Over the past 35 years, the Occupational Safety and Health Administration (OSHA) has progressively put more emphasis on training.

Training for New Hires

New employees should always receive what I call "Initial Safety Training." This session should give the employees insight on the general aspects of safety at your workplace. Everything from Personal Protective Equipment (PPE) and clothing to hazard communications should be covered in this initial training. This session should discuss safety issues that apply to all employees in the company.

The next level of training is "Task Specific Training." Normally, this type of training involves more than one session. These sessions cover topics unique to particular job descriptions-issues and situations that do not affect all employees in the company. For example, your field crews may need an extensive Permit Required Confined Space training session that lasts a day, while those in the office might need 30 minutes of training on the ergonomic aspects of computer use. One "must" of task specific training is that all field crews have detailed training on work zone traffic safety.

OSHA Training Definitions

To understand what may be required by OSHA, you should be familiar with the terms that OSHA frequently uses when discussing training. The following three definitions come from the OSHA Construction Regulations; 29 CFR 1926.32 (available on the web at www.osha.gov).

Authorized person: a person approved or assigned by the employer to perform a specific type of duty or duties or to be at a specific location or locations at the jobsite.

Competent person: one who is capable of identifying existing and predictable hazards in the surroundings or working conditions that are unsanitary, hazardous or dangerous to employees, and who has authorization to take prompt corrective measures to eliminate them.

Qualified person: one who, by possession of a recognized degree, certificate or professional standing, or who by extensive knowledge, training and experience, has successfully demonstrated his ability to solve or resolve problems relating to the subject matter, the work or the project.

Now let's apply these terms to OSHA's expectations. First, note that an authorized person is probably the least descriptive of OSHA's definitions. It can lead to a major trap: if you authorize someone without making certain he has received an adequate level of training, OSHA may still cite you. Worse yet, if you authorize someone without adequate training, he may get hurt or even hurt someone else. So you must be careful when you designate an employee as "authorized."

OSHA always expects a competent person to be in charge of safety for an activity or group of activities. Over the past 10 years OSHA has increasingly used its 10- and 30-hour outreach programs as an example of the level of training a competent person needs to achieve.

I am authorized to teach these classes by federal OSHA in both General Industry and Construction categories. One thing I have found after OSHA issues citations is that a company can often negotiate a significantly lower dollar amount of the citation by agreeing to conduct these classes for its employees. Depending on the size of the company, OSHA may request that one or two employees attend a 30-hour class, while all supervisors, foremen, line leaders, etc. attend a 10-hour class. My firm has even been involved in a few cases where OSHA asked that all employees attend a 10-hour class. Lately I have been hearing reports that some major construction projects now require all workers on the jobsite to have a minimum level of a 10-hour OSHA-approved class.

Make certain when you are scheduling 10- and 30-hour classes that the class you are attending is geared toward your industry. The class instructors must teach some specific topics, but hours in each class can also be devoted to industry specific topics. A surveyor attending a 10- or 30-hour class that never mentions traffic safety or confined spaces lacks a tremendous amount of very important information.

Some experts may disagree with me, but I feel the highest level of the three types of trained people is qualified (as opposed to competent). To be qualified implies a demonstration of ability. In school, we called that demonstration a test. Such a test may be written, oral or simply require someone to recognize problems. When I conduct classes for supervisory personnel, I like to take them into the field for a short trip. I allow them to view some hazardous situations and suggest solutions for what needs to be done to correct the hazards. This gives me an indication if they have retained some of the knowledge that I tried to pass on during the class. Some people are great at taking a written test but can't apply that knowledge in the real world. I prefer to see that employees understand the concepts, rather than see how great they are at taking tests.

Training Documentation

While you are in the process of implementing training for your employees, don't forget about documentation. It is a mistake to think that just providing the training to your employees is enough to satisfy an OSHA compliance officer. Documentation is the final step in any training class.

It makes no difference whether it is a weekly toolbox safety session or a 30-hour class, you MUST document the training! All training sessions, regardless of length, should begin by having employees sign in. On your sign-in sheet, make the employees actually sign their names and print their names beside the signature. For all but short toolbox talks, you may want to issue additional verification such as certificates or cards. Give one to each employee and then keep a copy for the employee's training file or your overall company safety training records.

If you undergo an inspection by OSHA or have a serious accident, having undeniable proof that employees were trained may save you a mint. I have been able to totally delete citations for clients because they kept complete verification of every employee's training records. Once I worked on a case where an employee told the compliance officer that he had never been trained on a particular area of safety, but the employer was able to provide four sheets from the previous three years with his signature proving that he had been trained.

Continue with Refresher Courses

You may think that once you have conducted training for all your employees that you have complied with all OSHA regulations (until a new employee is hired). But this is the wrong assumption to make. Some OSHA regulations require refresher training on a periodic basis. For example, the hazard communications regulations require an annual refresher session for all employees. The forklift training regulations require an evaluation every three years even after having an initial extensive training class. Anytime you introduce a new hazard into your workplace, you need to introduce a new safety training class.

The simple answer to our question of "How much safety training is enough?" is "An adequate amount to ensure the safety of your employees and anyone who could be affected by the actions of your employees." I guess maybe now I'll have to do an article to define "adequate." Stay safe by training safe!

OSHA Offerings

Training grants:OSHA awards grants each year to associations, educational institutions and other nonprofit entities; the grants are generally awarded for developing or conducting safety training.

OSHA Training Institute: The OSHA Training Institute (OTI) was formed as an educational facility to train OSHA compliance officers and other agency personnel; nongovernmental students are accepted when space allows. OTI's programs are also offered at regional outreach centers through OSHA partners; the majority of privately employed personnel are trained at these centers.

OSHA 10-and 30-hour Outreach programs: The 10- and 30-hour programs were developed in the 1990s as a tool to educate privately employed personnel who have responsibility for safety at their place of employment. The classes have developed into a major training program throughout the country. Both the 10- and 30-hour classes are conducted in General Industry and Construction. The 10-hour class teaches basics; the 30-hour class offers more detailed safety training.

Many construction projects now require a certain number of people from each company to have these levels of training. In addition to the construction and general industry classes, OSHA recently added an additional outreach training program on Disaster Response. It has the same basic parameters as the other two, but focuses on the safety of personnel responding to all types of disasters.

OSHA Training Requirements

OSHA has published a booklet more than 100 pages long that summarizes its training requirements. You can obtain the publication from OSHA at no charge or it can be downloaded from their website. Go to www.osha.gov and click on the Publications link. Scroll down to publication number 2254, Training Requirements in OSHA Standards and Training Guidelines. I recommend that you download the PDF onto your hard drive. You can then either view it at will or print it out. If you want to order a hard copy, the order can be placed from the same website. A basic knowledge of the OSHA Regulations will certainly help to understand the complexities of this document.