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?"
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:
- 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
Training Subject ____________________ Date _________
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
_______________ _______________ ___________
I have conducted orientation/on-the-job training to the 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 the employee has adequate knowledge, skills, and the ability, and is initially qualified to safely perform these procedures and/or practices.
________________ ________________ _________________
Trainer Name Signature Date
I observed/interviewed the above employee on __________ date(s). This employee has demonstrated adequate knowledge, skills, and ability, and is fully qualified to safely perform all steps of the procedures and/or practices in the work environment (at their workstation, worksite, etc.).
________________ ________________ _________________
Supervisor Name Signature Date
Notice that supervisor certification is included as part of the training document. The supervisor evaluates employee knowledge, skills and abilities on the job. Including this level of certification will help ensure employees are "fully qualified" to perform hazardous procedures and practices.
Sample Training Certification - Page 2
On this page, information about the subjects, performance exercises, and written tests is described. In this sample, the topic of training was the Hazard Communication.
You need written tests verify individual knowledge about a topic. Keep these written tests as attachments to the course plan and merely reference it here.
The following information was discussed with students: (check all covered subjects)
- ❏ Overview of the hazard communication program - purpose of the program
- ❏ Discussion of the hazards of chemicals to which students will be exposed
- ❏ GHS container labeling requirements
- ❏ Discussion of the 16 sections of the SDS and their location
- ❏ Emergency and Spill procedures
- ❏ First aid procedures
- ❏ 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
A written final exam was administered to the student and was successfully completed. A sample of the test is maintained in the course plan. Below is a partial sample of questions on the test:
- Where is the "Right to Know" station (or SDS station) located? (in the production plant)
- What PPE is required when exposed to ___? (short answer)
- How do you clean the PPE used with ___? (short answer)
- What are the emergency procedures for overexposure to ___? (short answer)
- Describe spill procedures for ___. (short answer)
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.