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?"
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:
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:
To make your documentation stronger, you may want to consider including the following information:
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.
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...
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)
The following practice/performance exercises were conducted:
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)
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.
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