Training Requirements in OSHA Standards and Training Guidelines
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Many standards promulgated by the Occupational Safety and Health Administration (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 to 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 Code of Federal Regulations Part 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 is 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 than would revise the training program to make it more effective, or conduct more frequent refresher training or some combination of these. The requirements of the Process Safety Management Standard follow the concepts embodied in the OSHA training guidelines contained in this booklet. The length and complexity of OSHA standards may make it difficult to find all the references to training. So, to help employers, safety and health professionals, training directors, and others with a need to know, OSHA's training-related requirements have been excerpted and collected in this booklet. Requirements for posting information, warning signs, labels, and the like are excluded, as are most references to the qualifications of people assigned to test workplace conditions or equipment. 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.
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