Documenting the Training

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 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?"

Safety and Health Instruction: Document with attendance rosters

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:

• date
• subject
• names attendees
• other identifying information

Technical Safety Training: Document with a formal certification

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:

• 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

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

(Page 1) 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 employees 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 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.

(Page 2) Sample Hazard Communication Training Outline 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 MSDS 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) What are the labeling requirements of a secondary container? (name of chem. and hazard warning) When does a container change from a portable to secondary container? (when employee loses control) What are the symptoms of overexposure to ___? (stinging eyes) Where is the "Right to Know" station (or MSDS 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) When should you report any injury to your supervisor? (immediately) What are the consequences if you do not follow safe procedures with this chemical (injury, illness, discipline)

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: OSHAcademy

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