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 only a good idea for the employer to keep a record of all safety and health training, it's required by more than 100 OSHA standards, and it's also recommended by ANSI Z490.1.
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 in a previous module, if your training or safety meeting presents general information or instruction related to safety, evaluation of knowledge and skills may be necessary. If evaluation of employee performance does not occur, it may be perfectly fine to use the attendance roster to document the training. 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 will normally not be adequate to document the training.
Technical safety training should document training with a formal certification. An attendance rotst just won't do. Certification of training usually involves issuing a certificate of competency or qualification. According to ANSI Z490.1-2001, 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 document 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.
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.
Supervisor Certification of Competency. I observed/interviewed the above employees on __________ date(s). Each employees demonstrated adequate knowledge and skills to safely perform all steps of the procedures/practices in the work environment (at their workstation, worksite, etc).
Notice that supervisor certification of competency is included as part of the training document. Supervisor certification illustrates "Level 3" evaluation which certifies employee knowledge and skills in the actual work environment. Including this will help ensure employees are "fully qualified" to perform hazardous procedures and practices.
On the second page of the document, information about the subjects, performance exercises, and tests is described. Let's take a look.
Sample Hazard Communication Training Outline
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)
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.
Source: OSHAcademyCertisafety Section Home Page
Copyright ©2000-2019 Geigle Safety Group, Inc. All rights reserved. Federal copyright prohibits unauthorized reproduction by any means without permission. Disclaimer: This material is for training purposes only to inform the reader of occupational safety and health best practices and general compliance requirement and is not a substitute for provisions of the OSH Act of 1970 or any governmental regulatory agency. CertiSafety is a division of Geigle Safety Group, Inc., and is not connected or affiliated with the U.S. Department of Labor (DOL), or the Occupational Safety and Health Administration (OSHA).