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Program Evaluation - OSHA

CFR 29 1910.120 App E is an effective guide for evaluating safety training.

OSHA Guidelines for Training Program Evaluation

OSHA's Occupational Safety and Health Standards, CFR 29, Subpart: H - Hazardous Materials 1910.120 App E Training Curriculum Guidelines, serves as an effective guideline for evaluating all safety training. To make sure your company conforms with this guideline, you should:

  • conduct or direct an annual written audit of the safety training program;
  • ensure the training provider formally documents, approves and implements program modifications to address deficiencies; and
  • maintain audit and the program modification documents at the training facility.

Check out OSHAcademy's comprehensive Ultimate Safety Training Program Audit that can help you cover all of the required audit areas per ANSI 490.1 and OSHA 1910.120.

1. According to 1910.120, Appendix E, Training Curriculum Guidelines, how often should the employer conduct a written audit of their training program?

a. Weekly
b. Monthly
c. Annually
d. Every five years

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Suggested Program Quality Control Criteria

CFR 29 1910.120 App E is an effective guide for evaluating safety training.

There are several suggested criteria for determining the quality and appropriateness of employee health and safety training.

Training Plan

The adequacy and appropriateness of the training program's curriculum development, instructor training, distribution of course materials, and direct student training should be considered. Below are some additional points and questions that should be considered as well.

  • The duration and frequency of training: Is it too short, just right, or too long? Is training conducted at the right time and often enough?
  • Course content: Is there too little, just enough, or too much?
  • Training requirements of the various target populations: Does the plan cover management training as well as employee training?
  • The process for the development of curriculum: Does it include appropriate technical input, outside review, evaluation, program pretesting?
  • The inclusion of hands-on, demonstration, and instruction methods: Do all students practice dangerous procedures and practices during the training?
  • Adequate monitoring: Is the trainer-student ratio adequate and is the learning environment safe for students?

2. Which of the following is a mandatory OSHA requirement when training hazardous procedures and practices?

a. Hands-on demonstration and practice
b. Required training length for each session
c. Company training compliance monitor
d. 10-question written exams

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Program Management, Training Director, Staff, and Consultants

The adequacy and appropriateness of training staff performance in delivering an effective training program should be considered. Below are some questions you should ask when evaluating program management and staff.

Management should always look at the adequacy of training.
  • How well does the training director demonstrate leadership in assuring quality of health and safety training?
  • To what degree do training staff show competency to meet the demands of delivering high quality safety training?
  • How clearly are staff duties defined?
  • What evidence shows that the training organizational structure suits the needs of the training program?
  • How appropriate and adequate are training methods used by the instructors?
  • Do the training director and staff devote adequate time to the training program?
  • Are human and physical resources adequate?

3. Which of the following questions would NOT be appropriate for evaluating training program management and staff?

a. How clearly are staff duties defined?
b. How appropriate and adequate are training methods used by the instructors?
c. How are trainers and staff disciplined if performance does not meet standards?
d. Do the training director and staff devote adequate time to the training program?

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Training Facilities and Resources


Training facilities and the resources required to conduct training need to be adequate and appropriate for safety training.

To assure the adequacy and appropriateness of the facilities, and the resources for supporting the training program, ask the following questions:

  • Is there adequate space and equipment to conduct the training?
  • Is there adequate lighting to conduct training?
  • Is the temperature and air quality of the training space controlled?
  • Is the quality of facilities adequate for conducting hands-on training?
  • Is the training space isolated from noise sources and unwanted interruptions?
  • In the case of multiple-site programs, are equipment and facilities located at the satellite centers?

4. Which of the following questions should be asked when considering the appropriateness of a training facility?

a. Can the training room also serve as the lunchroom?
b. Is temperature maintained to at least 74 deg F.?
c. Is low light used for night-time training?
d. Is the training space isolated from noise?

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Quality Control and Evaluation


It's important to set up programs to continuously evaluate the quality control function of the training plan. Questions about the adequacy and appropriateness of quality control and evaluation plans for training programs should focus on ensuring appropriate course evaluation, feedback, updating, and corrective action. The points below should be considered as well.

  • Do advisory committees and outside reviewers have the necessary experience and knowledge?
  • Does quality control and evaluation include instructor performance?
  • Do persons being used in the quality control and evaluation process have adequate expertise?
  • Are student evaluations used to provide feedback for training program improvement?

5. What is the value of using student evaluations for program evaluation?

a. They tell the trainer how much students like them
b. They provide feedback to help improve the program
c. They hold trainers accountable for the quality of training
d. They demonstrate compliance with OSHA regulations

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You can't have an effective training program without students! So, it's important to consider the adequacy and appropriateness of the program for accepting students.

This part of the evaluation should consider the questions below.

  • Is there documented assurance that the students already possess the necessary skills for their job? The new skills required by the student to safely perform their work should be constructed on the employee's current skills.
  • Are methods the program uses to ensure that students are capable of successfully completing training appropriate? Hands-on training, exercises, and proficiency assessment are essential.
  • Does the program comply with any medical clearance policy?

6. Which question should be asked by the training program evaluator regarding students?

a. Do students lack the ability to do the job being trained?
b. Do students already possess the necessary skills for their job prior to training?
c. Do students have to verify that they will complete the training?
d. Do students verify that training methods are appropriate?

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Institutional Environment and Administrative Support

Any effective safety training program will depend on the adequacy and appropriateness of the institutional environment and administrative support system.

To evaluate this part of the training program, be sure to consider the points below.

  • Is the organization's administrative structure and support adequate and appropriate for the training?
  • Does the organization's administration take advantage of the latest technology in documenting training program records?

7. What would the training program evaluator look for to help determine if the organization's administrative support is adequate?

a. Placement of written records
b. Administrative personnel attitudes
c. Use of the latest technology
d. Attendance at all training sessions

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Summary of Evaluation Questions

Below are key questions to consider for evaluating the quality and appropriateness of an overall training program.

  • Are the program objectives clearly stated?
  • Is the program accomplishing its objectives?
  • Are appropriate facilities and staff available?
  • Is there an appropriate mix of classroom, demonstration, and hands-on training?
  • Is the program providing quality employee health and safety training that fully meets the intent of regulatory requirements?
  • What are the program's main strengths?

8. When evaluating the training program, you should ask if there is _____ classroom, demonstration, and hands-on training.

a. a dependence on
b. a reliance on
c. a focus on
d. an appropriate mix of

Check your Work

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About OSHA Training Requirements

OSHA training requirements include the fact that each employee has to be trained in the hazards that they may encounter during work. Discover how this training can vary greatly with information from an OSHA-authorized trainer in this free video on OSHA training requirements. Bob Emmerich has over 31 years of experience in safety, construction project management, operations management and engineering.

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