Training Requirements In OSHA
Standards
Why do we even have OSHA?
4,383 workers were killed on the job in 2012
– 3.2 per 100,000 full time workers
– 84 per week
– 12 deaths every day
40,961 Total Federal Inspections
51,133 Total State inspections
Since 1970, workplace fatalities have been reduced
by more than 65%
Top 10 Most Cited OSHA Standards
Violations in FY13
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1. Fall protection, construction (29 CFR 1926.501) [related OSHA Safety and Health Topics
page]
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2. Hazard communication standard, general industry (29 CFR 1910.1200) [related OSHA Safety
and Health Topics page]
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3. Scaffolding, general requirements, construction (29 CFR 1926.451) [related OSHA
Safety and Health Topics page]
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4. Respiratory protection, general industry (29 CFR 1910.134) [related OSHA Safety and
Health Topics page]
5. Electrical, wiring methods, components and equipment, general industry (29 CFR 1910.305)
[related OSHA Safety and Health Topics page]
6. Powered industrial trucks, general industry (29 CFR 1910.178) [related OSHA Safety and
Health Topics page]
7. Ladders, construction (29 CFR 1926.1053) [related OSHA Safety and Health Topics page]
8. Control of hazardous energy (lockout/Tagout), general industry (29 CFR 1910.147)
[related OSHA Safety and Health Topics page]
9. Electrical systems design, general requirements, general industry (29 CFR 1910.303)
[related OSHA Safety and Health Topics page]
10.Machinery and Machine Guarding, general requirements (29 CFR 1910.212) [related
OSHA Safety and Health Topics page
The 10 most common documents an
OSHA inspector might ask to see……
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1. OSHA 300 Log
2. Lockout/Tagout Program
3. Process Safety Management
4. Emergency Action Plan
5. Respirator Program
6. Confined Space
7. Portable Fire Extinguishers
8. Hazard Communication
9.Hazard Assessment
10. Hearing Conservation
– Training Requirements
• How many of you think that there are certain
mandatory training requirements each year?
• How many think that there are not any
mandatory training requirements but do
conduct some kind of required training?
Different OSHA Standards
• 1903 Inspections, Citations
AND Proposed Penalties
1904 Recording and
Reporting Occupational
Injuries and illness
• 1910 General
Industrial
• 1926 Construction
Horizontal and Vertical Standards
• Some standards are horizontal meaning
“general”, or “across the board”
• Horizontal standards could apply to any
employer in any industry
• Examples of horizontal standard:
– Hazard Communication Standard
– Walking and Working Surfaces
Horizontal and Vertical Standards
• Vertical standards are
specific only to a particular
industry:
– Pulp, paper, and paperboard
mills (1910.261)
– Textiles (1910.262)
– Sawmills (1910.265)
– Logging operations
(1910.266)
• No Federal vertical standard
for oil and gas well drilling
or servicing
Voluntary Training Guidelines
• The Occupational Safety and Health Act of
1970:
– “does
not address specifically
the responsibility of the
employers to provide health
and safety information to
employees”
;although Section 5(a)(2) does
require that each
employer”……shall comply with
occupational safety and health
standards promulgated under this
Act”
General Industry Training
Requirements
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1910.181 – Derricks (material handling)
1910.183 – Helicopters (for material handling)
1910.184 – Slings (material handling)
1910.217 – Mechanical Power Presses
1910.218 – Forging Machines
1910.252 – 1910.255 – Welding, Cutting and
Brazing
1910.261 - Pulp, Paper, and Paperboard Mills
1910.262 – Textiles
1910.264 - Laundry Machinery and Operations
1910.265 – Sawmills
1910.38 - Emergency Action Plans
1910.39 - Fire Prevention Plans
1910.66 - Powered Platforms for Building
Maintenance
1910.95 – Occupational Noise Exposure
1910.106 – Flammable and Combustible Liquids
1910.109 - Explosive and Blasting Agents
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1910.124 - General Requirements for Dipping
and Coating Operations
1910.132 – Personal Protective Equipment
1910.134 – Respiratory Protection
1910.142 - Temporary Labor Camps
1910.145 - Specifications for Accident
Prevention Signs and Tags
1910.146 – Permit Required Confined Spaces
1910.147 – The Control of Hazardous Energy
(lockout-Tagout)
1910.151 - Medical Services and First-Aid
1910.155 – 1910.165 – Fire Protection (includes
portable fire extinguishers)
1910.177 - Servicing of Multi-Piece and SinglePiece Rim Wheels
1910.178 – Powered Industrial Trucks (forklift
operator training)
1910.179 – Overhead and Gantry Cranes
1910.180 – Crawler, Locomotives and Truck
Cranes
General Industry Training
Requirements, cont………
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1910.266 – Logging Operations
1910.268 – Telecommunications
1910.269 - Electric Power Generation,
Transmission, and Distribution
1910.272 – Grain Handling Facilities
1910.332 – 1910.333 – Electrical Safety Related
Work Practices
1910.410 – 1910.440 - Commercial Diving
Operations
1910.1000 – Toxic and Hazardous Substances
1910.1001 – Asbestos
1910.1003 – 1910.1016 – Thirteen Carcinogens
1910.1017 – Vinyl Chloride
1910.1018 – Inorganic Arsenic
1910.1020 - Access to Employee Exposure and
Medical Records
1910.1025 – Lead
1910.1026 - Chromium (VI)
1910.1027 – Cadmium
1910.1028 – Benzene
1910.1029 - Coke Oven Emissions
1910.1030 – Bloodborne Pathogens
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1910.1043 – Cotton Dust
1910.1044 - 1,2-Dibromo-3-Chloropropane
1910.1045 - Acrylonitrile (Vinyl Cyanide)
1910.1047 - Ethylene Oxide
1910.1048 – Formaldehyde
1910.1050 – Methylenedianiline
1910.1051 - 1,3-Butadiene
1910.1052 - Methylene Chloride
1910.1096 – Ionizing Radiation
1910.1200 – Hazard Communication
1910.1450 - Occupational Exposure to
Hazardous Chemicals in Laboratories
ADMINISTRATIVE REQUIREMENTS
1903.2 - Posting of Notice; Availability of the
Act, Regulations and Applicable Standards
1904.35 - Injury and Illness Recordkeeping
Requirements - Employee Involvement
OSHA Guidelines
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A. Determining if Training is Needed
B. Identifying Training Needs
C. Identifying Goals and Objectives
D. Developing Learning Activities
E. Conducting the Training
F. Evaluating Program Effectiveness
G. Improving the Program
Is Training the Solution?
• Some experts believe that training should only
be provided after all other performance issues
have been addressed.
• As you evaluate the potential hazards during
your worksite analysis, try to determine if any
other issues could be contributing to the
performance problem before choosing
training as the solution.
Identifying If Training is Needed:
Your worksite analysis, may help you discover
additional areas where training will be beneficial.
• Accident investigation of a hand injury may show
that the employee had not been properly trained
in lockout / Tagout procedures.
• Self-inspection may show that employees were
working in confined spaces without having
received any training in this area.
• A JHA may show that employees are improperly
lifting boxes because they have not been trained
in proper lifting techniques.
Job Hazard Analysis “JHA”
• Not required by Federal OSHA
– But, employers are required to take necessary steps to
ensure safety.
• 1910.132 (d) (2): The employer shall verify that the required
workplace hazard assessment has been performed through a
written certification that identifies the workplace evaluated;
the person certifying that the evaluation has been
performed; the date(s) of the hazard assessment; and , which
identifies the document as a certification of hazard
assessment.
– Some state may require/accept it as part of an I2P2,
IIPP or similar “safety program” requirement
Breaking Down the Term “JHA”
• Job = tasks (changing a light bulb, chocking a
trailer, grinding a part)
• Hazard = caught-in, struck-by, chemical,
ergonomic … anything that can cause harm
• Analysis = Talking with operators, watching job
being performed, breaking down into steps,
identifying hazards, implementing controls
JOB SAFETY ANALYSIS FORM
JOB/TASK NAME:
PAGE
EMPLOYEE(S)/POSITION(S) PERFORMING THE JOB:
SUPERVISOR(S):
ANALYSIS BY:
COMPANY NAME:
DEPARTMENT(S):
REVIEWED BY:
SHIFT(if applicable):
APPROVED BY:
PLANT/LOCATION:
PERSONAL PROTECTIVE EQUIPMENT:
JOB STEPS
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POTENTIAL HAZARDS
OF
DATE:
NEW
REVISED
ACTION/PROCEDURE TO CONTROL OR ELIMINATE
Risk Management is Managing Risk
• What is the tolerance for risk ?
– Accept low risk
• Cost of risk low
• Consequences of risk low
• Duration of the risk
– Can not accept risk
• Frequency is high
• Consequences high
• Costs are high
Direct Costs of Injuries
and Illnesses
• Direct costs of the most
disabling workplace
injuries in the U.S.
averaged $47.6 billion
per year between 1998
and 2008
Consequences
Likelihood
Almost certain
Severe
Major
Medium
Minor
Negligible
(1)
(2)
(3)
(4)
(5)
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T
(A)
Likely
(B)
Possible
(C)
Unlikely
(D)
Rare
(E)
Key to risk rating
• Extreme Risk – Immediate action required; this
level of risk need detailed research and planning
by senior management.
• High Risk – Action plan is required as soon as
practicable by senior management
• Moderate risk – Action plan is required by
Area/Department Manager
• Low risk – Managed by routine procedures and
employees under supervision
• Trivial risk – Unlikely to need specific application
of resources
Some Industries Horizontal Standards
• Requirements for
Every Business
• Basic Safety Training
• Personal Protective Equipment
• Emergency Action Plan
• Fire Prevention
• Hazard Communication
• Exit Routes
• Walking/Working Surfaces
• Medical and First Aid
• Injury/Illness Reporting
• Bloodborne Pathogens
• Additional Requirements for
High Risk,
Construction, and
Manufacturing
• Machine Guarding
• Lockout/Tagout
• Electrical Hazards
• Respirators
• Noise Protection
• Confined Spaces
IF TRAINING IS DONE…………
• Initial training is required before you start
your job.
• Annual training is training that occurs every
year for certain occupations including medical
and environmental occupations.
• Special incremental training is training that
occurs every other year or every three years,
and potential hazard training is required when
companies identify new hazards.
IF TRAINING IS DONE…………
• It must use both a language and vocabulary
that the employee can understand.
• Requirements related to employee
comprehension
Identifying Training Requirements
• Some standards might require different levels of
training, depending on the worker's level of
exposure to the hazard.
• Employees who actually perform the work would
need extensive training; other employees may
just need to know that the hazard exists
• Multiple levels of training may be explicitly
stated.
Training Requirements?
• OSHA explicitly require the employer to train
employees in the safety and health aspects of
their jobs.
• Others limit certain job assignments to
employees who are “certified”, “competent”
or “qualified”
Terminology
Certified
Certified A “Certified” person is authoritatively or officially attested or confirmed
as being genuine or true as represented, or as complying or meeting specified
requirements or standards. It may or may not mean as being accompanied by a
certificate.
Competent
The term “competent person” is used in many Occupational Safety and Health
Administration (OSHA) standards and documents. An OSHA “competent person” is
defined as “one who is capable of identifying existing and predictable hazards in
the surroundings or working conditions which are unsanitary, hazardous, or
dangerous to employees, and who has authorization to take prompt corrective
measures to eliminate them”.
Qualified
Qualified A qualified person is one who, by possession of a recognized degree, certificate, or
professional standing, or who by extensive knowledge, training and experience, has
successfully demonstrated his ability to solve or resolve problems relating to the subject
matter, the work, or the project.
Terminology Continued……
Designated Person
The term “designated” personnel means employees selected or assigned by the
employer or the employer’s representative as being qualified to perform specific duties.
The Lockout/Tagout standard distinguishes between "authorized
employee training", "affected employee training" and "all other
employee training".
• Authorized employee training is for workers who perform
maintenance on equipment.
• Affected employee training is for workers whose job may require
regular use of the equipment but not involve maintenance or repair
on it.
• All other employee training is for workers whose work operations are
or may be in an area where lockout/Tagout is utilized
Is Training the Solution?
• Training is an appropriate solution to
performance problems when there is a deficiency
of knowledge or skills.
• Suppose your company experiences safety
performance problems such as employees
working with guards removed from machinery or
not wearing the proper personal protective
equipment (PPE).
• Company pressure to work too quickly or
improper sizing of PPE may be the underlying
causes of these behaviors, not lack of knowledge.
Document, Document, Document…
• Document all training for proof of training.
– Although not required by standard, must prove
that the worker understands the training
• Records need to be kept for at least one year
to show current training.
• OSHA Logs Form 300 must be kept for five
years following the year to which they pertain.
Can You Name the For Basic Areas
That OSHA requires Witten
Documentation?
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1. Safety Program
2. Documenting of Hazard Assessment
3. Maintaining of Training Records
4. Certification of Training Given to Employees
GENERAL DUTY CLAUSE
• Conditions must be met for OSHA to issue:
– The hazard was recognized
– The employer failed to keep the workplace free of
hazard to which his or her employees were
exposed
– A feasible and useful method was available to
correct the hazard
– The hazard was causing or likely to cause death or
serious injury.
Summary
• Training is voluntary and OSHA does not
intend to make the guidelines mandatory
– OSHA encourages a personalized approach to the
informational and instructional programs at
individual worksites, thereby enabling employers
to provide the training that is most needed and
applicable to local worksites
• Must Determine if training is needed and
Identifying what training pertains to them
Summary Cont……………
• The adequacy of employee training may also
become an issue in contested cases where the
affirmative defense of unpreventable employee
misconduct is raised.
• Documentation is key to proof of training and its
effectiveness
• If not a defined OSHA hazard it can still fall under
the General Duty Clause
• Not the end….but the beginning
of SAFETY
Questions?