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What does OSHA say about training frequency? What documentation is required?

On this week’s episode of Dynamic Discussions, Greg and David interview a special guest from Trivent Safety Consulting in Colorado, Bryan McClure. What does OSHA say about training frequency? And what documentation is required?

Trivent encourages their clients to train weekly/ continuously. Equipment certification is required by OSHA and documentation is part of the requirement. Always keep your documentation on file. When OSHA comes on site for an accident, or inspection, or any reason. Having a written down and well documented fall protection plan, hazard analysis, training plan, and rescue plan with sign-in sheets, it makes defending yourself and your practices much easier.

What’s the Biggest Mistake Safety Managers Make?

Bryan says that safety managers, especially new ones, tend to take on a personality that makes the workers feel like they are being called out without being instructed on what’s wrong or not compliant. Having well documented and active safety precautions is definitely a favored, but that doesn’t mean to just be a ‘safety cop’. Don’t beat the workers up about what’s wrong, turn that negativity into a coaching and learning opportunity. The safety managers should be setting a good example to worker with their own safety measures and shouldn’t just match around the jobsite taking pictures and submitting non-compliance reports without interacting with their crew. It’s extremely important to actively educate workers on the correct safety measures and compliances to be aware of. People are much more inclined to adopt safety measures if they are treated as an equal and educated properly, instead of feeling like they’re being policed.

OSHA Training Requirements

The following training provisions supplement and clarify the requirements of 1926.21 regarding the hazards addressed in subpart M of this part.

1926.503(a) – “Training Program.”

1926.503(a)(1) The employer shall provide a training program for each employee who might be exposed to fall hazards. The program shall enable each employee to recognize the hazards of falling and shall train each employee in the procedures to be followed in order to minimize these hazards.

1926.503(a)(2) The employer shall assure that each employee has been trained, as necessary, by a competent person qualified in the following areas:

1926.503(a)(2)(i) The nature of fall hazards in the work area;

1926.503(a)(2)(ii) The correct procedures for erecting, maintaining, disassembling, and inspecting the fall protection systems to be used;

1926.503(a)(2)(iii) The use and operation of guardrail systems, personal fall arrest systems, safety net systems, warning line systems, safety monitoring systems, controlled access zones, and other protection to be used;

1926.503(a)(2)(iv) The role of each employee in the safety monitoring system when this system is used;

1926.503(a)(2)(v) The limitations on the use of mechanical equipment during the performance of roofing work on low-sloped roofs;

1926.503(a)(2)(vi) The correct procedures for the handling and storage of equipment and materials and the erection of overhead protection; and

1926.503(a)(2)(vii) The role of employees in fall protection plans;

1926.503(a)(2)(viii) The standards contained in this subpart.

1926.503(b) – “Certification of training.” 1926.503(b)(1) The employer shall verify compliance with paragraph (a) of this section by preparing a written certification record. The written certification record shall contain the name or other identity of the employee trained, the date(s) of the training, and the signature of the person who conducted the training or the signature of the employer. If the employer relies on training conducted by another employer or completed prior to the effective date of this section, the certification record shall indicate the date the employer determined the prior training was adequate rather than the date of actual training. 1926.503(b)(2) The latest training certification shall be maintained.

1926.503(c) “Retraining.” When the employer has reason to believe that any affected employee who has already been trained does not have the understanding and skill required by paragraph (a) of this section, the employer shall retrain each such employee. Circumstances where retraining is required include, but are not limited to, situations where:

1926.503(c)(1) Changes in the workplace render previous training obsolete; or

1926.503(c)(2) Changes in the types of fall protection systems or equipment to be used render previous training obsolete; or

1926.503(c)(3) Inadequacies in an affected employee’s knowledge or use of fall protection systems or equipment indicate that the employee has not retained the requisite understanding or skill.

Note: The following appendices to subpart M of this part serve as non-mandatory guidelines to assist employers in complying with the appropriate requirements of subpart M of this part. [59 FR 40738, Aug. 9, 1994; 60 FR 5131, Jan. 26, 1995]

Source: Occupational Safety and Health Standards. 1910.140 – Personal fall protection systems. | Occupational Safety and Health Administration. (n.d.). Retrieved January 11, 2022, from https://www.osha.gov/ laws-regs/regulations/standardnumber/1910/1910.140

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