February 2005 Safety Tip

OSHA Requirements

This month's Safety Tip, Safety Training - OSHA's requirements, is based on Maricopa County's Safety and Liability Policies - A2200 and the Occupational Safety and Health Act. Each set of documents require that both the employer AND the employee follow guidance to establish and maintain a safe working environment. Both also recognized that there are many situations where specific training would be required in order reach this goal.

The Occupational Safety and Health Administration (OSHA) understood that the length and complexity of its various standards could make it difficult to find references for all required training. Therefore, in an effort to help employers, safety and health professionals, training managers, and others with a need to know, OSHA compiled the various training requirements into its publication, "Training Requirements in OSHA Standards and Training Guidelines," OSHA publication OSHA 2254. OSHA did not include information such as information posting, warning signs, or labels, as well as references to qualifications of persons who test workplace conditions or equipment.

The following is from the introduction of this guidance:

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. Many researchers conclude that those who are new on the job have a higher rate of accidents and injuries than more experienced workers.

If ignorance of specific job hazards and of proper work practices is even partly to blame for this higher injury rate, then training will help provide a solution.

As an example of the trend in OSHA safety and health training requirements, the Process Safety Management of Highly Hazardous Chemicals standard (Title 29 CFR 1910.119) contains several training requirements promulgated under the requirements of the Clean Air Act Amendments of 1990. This Standard requires the employer to evaluate or verify that employees comprehend the training given to them, meaning that the training must have established goals and objectives regarding what is to be accomplished. Subsequent to the training, an evaluation would be conducted to verify that the employees understood the materials presented or acquired the desired skills or knowledge. If the goals and objectives were not achieved, then the employer must revise the training to make it more effective, conduct more frequent refresher training, or both.

Training in the proper performance of a job is time and money well spent, and the employer [and employee] might regard it as an investment rather than as an expense [or extra time-consuming step]. 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.