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Course 721 - Developing OSH Training

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Documenting the Training

Remember, as far as OSHA is concerned... If it isn't in writing, it didn't get done!

Protect the Employee and the Employer

As a member of your employer's safety staff, it's not only your responsibility to help protect employees, it's also your obligation to help protect the employer. One of the best ways to do that is to ensure strong safety training documentation.

It's not just a good idea for the employer to keep complete and accurate records of all safety and health training, it's required by more than 100 OSHA standards, and it's also recommended by ANSI Z490.1-2016.

Records can provide evidence of the employer's good faith effort to comply with OSHA standards. Strong documentation can also help the employer defend against claims of negligence. Documentation can also supply an answer to one of the first questions an accident investigator will ask: "Was the injured employee adequately trained to do the job?"

Attendance Rosters

roster
Sample Attendance Roster
(Click to enlarge)

As we learned before, if your training or safety meeting presents general information related to safety it's most likely considered safety "instruction." Since we do not need to evaluate employee performance to determine the ability to perform hazardous tasks or procedures, it may be perfectly fine to use a standard attendance roster to document safety instruction. An attendance roster may include the following information:

  • Date
  • Subject
  • Names attendees
  • Other identifying information

Formal Certification of Training

When safety training requires employees to demonstrate knowledge and skills in performing hazardous procedures or using safe practices, an attendance roster may not be legally sufficient to document the training.

Technical safety training should include a formal certification. Certification of training usually involves issuing a certificate of competency or qualification. According to ANSI Z490.1-2016, Section 7.4, Issuing Certificates, recommended certification of training should include:

  • Trainee's name
  • Course title
  • Date, location and hours of instruction
  • Statement that the trainee has successfully completed the course
  • Name and address of training provider
  • Date periodic refresher training is due (if required) or expiration date
  • A unique trainee identification number
  • The level of training or type of certificate awarded
  • Any other information required by regulation
  • Number of credits (CECs, CEUs, etc), if issued. Make sure employees have met all requirements for credits.

To make your documentation stronger, you may want to consider including the following information:

  • Trainee statement that he/she was provided opportunity to ask questions and perform procedures and practices.
  • Trainer statement that trainees, through testing, demonstrated adequate knowledge.
  • Trainer statement that measurement (testing) of knowledge and skills was conducted and that trainees met or exceeded required levels of performance
  • Trainee statement of intent to comply with the procedures, practices, policies, and rules.
  • Trainee statement of understanding that failure to comply may result in discipline
  • A list or description of the specific subject(s) being trained. Describe the safety procedures, practices, policies, rules addressed in training.
  • A list or description of the specific procedures practiced in the learning environment.
  • Certification - a place for trainee and trainer signatures

Sample Training Certification - Page 1

See the sample training certification below to get a better idea what may be included:


Training Subject ____________________ Date _________ Location _______________

Trainee Certification of Training. I have received on-the-job training on those subjects listed (see other side of this sheet): This training has provided me adequate opportunity to ask questions and practice procedures to determine and correct skill deficiencies. I understand that performing these procedures/practices safely is a condition of employment. I fully intend to comply with all safety and operational requirements discussed. I understand that failure to comply with these requirements may result in progressive discipline (or corrective actions) up to and including termination.

Employee Name Signature Date
___________ ___________ ___________
___________ ___________ ___________

Trainer Certification of Competency. I have conducted orientation/on-the-job training to each employee listed above. I have explained related procedures, practices and policies. Each employee was given opportunity to ask questions and practice procedures in the learning environment. Based on each student's performance, I have determined that each employee trained has adequate knowledge and skills to safely perform these procedures/practices.

__________________
Trainer Name
__________________
Signature
__________________
Date

Supervisor Certification of Competency. I observed/interviewed the above employees on __________ date(s). Each employee demonstrated adequate knowledge and skills to safely perform all steps of the procedures/practices in the work environment (at their workstation, worksite, etc).

__________________
Supervisor Name
__________________
Signature
__________________
Date

Notice that supervisor certification of competency is included as part of the training document. Supervisor certification indicates the results of the evaluation of employee knowledge and skills in the actual work environment. Including supervisor certification will help ensure employees are "fully qualified" to perform hazardous procedures and practices. It also gives the employer stronger documentation on training if OSHA should want to see it.

On the second page of the certification, information about the subjects, performance exercises, and tests is described. Let's take a look...

Sample Training Certification - Page 2

The benefit of including this second page in the document is that it can also serve as a lesson plan for your training. The learning objects you've written will help you develop the list of subjects and performance exercises. It outlines the subjects and exercises that need to be conducted to make sure required training is accomplished.

The following information was discussed with students: (check all covered subjects)

  • Overview of the hazard communication program - purpose of the program
  • Primary, secondary, portable, and stationary process container labeling requirements
  • Discussion of the various sections of the SD'S and their location
  • Emergency and Spill procedures
  • Discussion of the hazards of the following chemicals to which students will be exposed
  • Symptoms of overexposure
  • Use/care of required personal protective equipment used with the above chemicals
  • Employee accountability

The following practice/performance exercises were conducted:

  • Spill procedures
  • Emergency procedures
  • Personal protective equipment use

The following written test was administered: (Or "Each student was asked the following questions:") (Keep these tests as attachments to the safety training plan and merely reference it here to keep this document on one sheet of paper)

  1. What are the labeling requirements of a secondary container? (name of chemical. and hazard warning)
  2. When does a container change from a portable to secondary container? (when employee loses control)
  3. What are the symptoms of overexposure to ___? (stinging eyes)
  4. Where is the "Right to Know" station (or SD'S station) located? (in the production plant)
  5. What PPE is required when exposed to ___? (short answer)
  6. How do you clean the PPE used with ___? (short answer)
  7. What are the emergency procedures for overexposure to ___? (short answer)
  8. Describe spill procedures for ___. (short answer)
  9. When should you report any injury to your supervisor? (immediately)
  10. What are the consequences if you do not follow safe procedures with this chemical (injury, illness, discipline)

Instructions

Before beginning this quiz, we highly recommend you review the module material. This quiz is designed to allow you to self-check your comprehension of the module content, but only focuses on key concepts and ideas.

Read each question carefully. Select the best answer, even if more than one answer seems possible. When done, click on the "Get Quiz Answers" button. If you do not answer all the questions, you will receive an error message.

Good luck!

1. One of the best ways you can help to protect your employer is to ensure _____.

2. In most instances, for technical safety training, documentation should be a _____.

3. An attendance roster that lists date, subject, and names of those attending, may be sufficient as a training document for this type of training.

4. Maintaining adequate training records can do all of the following, EXCEPT _____.

5. Which of the following is not listed in the text as a method to make your documentation stronger?


Have a great day!

Important! You will receive an "error" message unless all questions are answered.