Presented By David F. Coble, MS, CSP. Safety Associates

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1 OSHA Required Training Presented By David F. Coble, MS, CSP Coble, Taylor & Jones Safety Associates t

2 David F. Coble, MS, CSP 36 years of safety experience including 12 y y p g years with NC OSHA and 24 years in consulting and training OSHA Required Training and Inspections frequent training and speaking topic Professional Member of ASSE and Member of Standards Development Committee Director on the Board of Certified Safety Professionals Chair of ANSI B15.1 Committee

3 Other Resources The Safety Professionals Handbook Management Applications Section 4 Safety and Health Training and ASSE Webinar Provided on April 14, 2009

4 Goals Review OSHA Required Training Found in 1910 and 1926 Discuss Certification Records, Trainer Requirements and Subject Matter Review OSHA Expectations Found in OSHA Letters of Interpretation and My Own Experience

5 OSHA Required Training Number of OSHA Training and Inspection Requirements 190 General Industry Training Rules 140 Construction Training Rules 250 General Industry Inspection Rules 150 Construction Inspection Rules

6 For a Free Copy of CTJ Safety Associates Checklists OSHA Required Training for General Industry OSHA Required Training for Construction E Mail me at davidcoblecsp@aol.com

7 Approximately 730 OSHA 1910 and 1926 Standards That Require Training and Inspections (Not Counting The Standards Incorporated by Reference plus General Duty Obligations) Access to Records Aerial Lifts Bloodborne Pathogens Confined Spaces Ladders Scaffolds Signs and Tags Slings Welding

8 Nearly 200 Documents Incorporated by Reference Professional Organization s Documents (API, CGA, etc.) Welding Manuals Underwriter s Lab Standards Consensus Standards (ANSI, NFPA, etc.) For Example

9 Compressed Gas Assoc. Pamphlet P-1 Requires Training for Those Who Handle and Use Gas Cylinders (b)

10 Another Example, The Owner s Manual of the Welding Machine Requires Training (d)(6)

11 OSHA General Industry Vs. Construction Differences Scaffolds Construction has a training requirement General Industry does not The hazard is the same

12 General Industry Vs. Construction Differences Fall Protection Construction has a training requirement General Industry does not The hazard is the same.

13 General Industry vs Construction Differences Construction has Generic Training Requirements ( ) General Industry Does Not!

14 Many Standards Require Only Initial Training i Ladder Usage and Inspection [ ] Danger Signs and Tags [ (c)] 145(c)] Overhead and Gantry Crane Operators [ (b)(8)] 179(b)(8)] Sling Inspections [ (d)] Welding, Burning and Cutting [ ,.253 and.254 and (d) and.351(d)]

15 Some Standards Require Initial Training and Repeat Training if There are Problems or Changes Emergency Action Plans [ (f)] Personal Protective Equipment [ (f)(3)] )] Permit Confined Spaces [ (g)(2)] Powered Industrial Trucks [ (l)(4)] 178(l)(4)] Fall Protection [ (c)] For Example

16 Arrow indicates where the employee was pinned beneath the overhead canopy.

17 Was the floor of this trailer inspected before entry?

18 Could training for this worker be deficient? i

19 Could training for this worker be deficient? What if?? - Moving vehicles are present? - The weed eater throws a rock at him? - He stumbles upon a wasp nest? - It is a 104 F day?

20 A Few Standards Require Evaluation of Training and Then Followup If There are Problems Personal Protective Equipment [ (f)(3)] Confined Spaces Rescue [ (k)(1)(i)] Wheel Rims [ (c)(3)] For Example

21 Multi-Piece and Single Piece Rim Wheels 29 CFR

22 Multi-Piece and Single Rim Wheels Standard Includes: Large Trucks Buses Trailers Off-road Machines Does Not Include: Automobile Tires Light Truck Tires Designated LT

23 Mechanic Killed by Exploding Tire NIOSH FACE Report #05CA007 May 25, 2005 Apprentice mechanic checking air pressure on a military wheel Stood over the tire and used a wrench to adjust the bolts on the flange Tire exploded and killed mechanic

24 Multi-Piece and Single Piece Rims Multi-Piece: Inflate only if 80% inflated and using remote control inflation equipment, and out of trajectory Single Piece: Inflate only if all lug nuts fully tight

25 Multi-Piece and Single Rim Wheels Protection Restraining Device For Single or Multi-piece Barrier For Single Piece Only

26 Written Certification of Training There are about a dozen standards that require a written certification record of the training. This must include the employee s name, the signature of the trainer and the dates of the training. For example

Written Certification Record of Training About 25 Requirements

503(b)(1) Building Powered Platforms 1910.

119(g)(3) Personal Protective Equipment 1910.

27 Written Certification Record of Training About 25 Requirements Confined Spaces (g)(4) Fall Protection (b)(1) Building Powered Platforms (i)(1)(v) ) Process Safety Management (g)(3) Personal Protective Equipment (f)(4) Lockout (c)(7)(iv) Powered Industrial Trucks (l)(6) 178(l)(6) Telecommunications (c) Bloodborne Pathogens (h)(2)

28 Typical Certification Record CTJ Safety Associates FALL PROTECTION TRAINING ROSTER Certification of Training in Accordance with (b) Page 1 of 1 Date of Training Employee Name Work Location Initials Trainer s Signature: Date:

29 Requirement for Qualified Trainer About 12 Requirements Hazwoper (e)(3)(i) - (iii) Fall Protection (a)(2) Building Powered Platforms (i)(1)(iii) Scaffolds (a)(1) and (b)(1) Mobile Cranes (h)(3)(xii) Respirator Program Administrator (c)(3) Emergency Response (q)(7) Powered Industrial Trucks (l)(2)(iii) Overhead Cranes (n)(3)(ix) Bloodborne Pathogens (g)(2)(viii)

30 39 OSHA Standards Require Initial and Annual Training Hearing Conservation [ (k)(2)] Respirator Users [ (k)(5)] 134(k)(5)] Fire Extinguisher Users [ (g)] Access to Exposure and Medical Records [ (g)(1) and ] Bloodborne Pathogens [ (g)(2)]

31 Training Fundamentals Annual means every 365 days to OSHA OSHA has expectations for Computer Based training (OSHA Letter of Interpretation to Nancy Wickler dated January 15, 1999) Keep a record of all training indefinitely Train to a level so that the employee can do the job safely (i.e., electrical l work practices)

32 Different Levels of Training Would Be Expected (a) (a)(2)

33 Training Fundamentals Annual means every 365 days to OSHA OSHA has expectations for Computer Based training Keep a record of all training indefinitely Train to a level so that the employee can do the job safely (i.e., electrical l work practices) Your employees can not do effective inspections until they have been trained; for example

or ring-test to ensure free from cracks / defects To test: tap wheel

34 Inspecting Abrasive Wheels (d)(1) Before mounting: inspect closely l for damage perform sound- or ring-test to ensure free from cracks / defects To test: tap wheel gently with a light, non-metallic instrument if wheel sounds cracked or dead, do not use it because it could fly apart

36 In other words, there are quite a few regulatory required training topics! This must be managed. OSHA s Recommended Training Management System?...

37 OSHA s Voluntary Training Guidelines Issued July 27, 1984 (1) determine whether a worksite problem can be solved by training; g;( (2) determine what training, if any, is needed; (3) identify goals and objectives for the training;(4) design leaning activities; (5) conduct training; (6) determine the effectiveness of the training; and (7) revise the training program based on feedback from employees, supervisors, and others.

38 The ANSI/ASSE Z490.1 (2009) standard was developed to improve the consistency and quality of training development, delivery, evaluation and management.

39 1 st Key Issue for Effective Training Content What They Need to Know 1. Do a Needs Assessment Use the CTJ Safety Checklists on required training as a starting point, i.e.

40 1 st Key Issue for OSHA Required Training What They Need to Know 1. Do a Needs Assessment Use the CTJ Safety Checklists on required training as a starting point Walkthrough audits, interviews, incident reports, safety meeting minutes And, the following

41 Needs Assessment Use the Following Documents OSHA Standards State and Federal Consensus Standards Manufacturer s Instructions and Manuals Local Codes and Laws Association Guides

42 Content What They Need to Know 1. Needs assessment 2. Develop a matrix or chart of required training

43 Training Topics Details** Mechanics Helpers Machinists Aerial llifts H3W H, 3, Asbestos C, A, W Bloodborne Pathogens Burning/ Cutting CB, A, W H, I, P Chemicals CB, T, I, W Confined Spaces C, H, A, P Emergencies C, A, W Etc. From A to Z ** H = Hands On, T = Tool Box, C = Classroom, CB = Computer Based, A = Annually, I = Initially, 3 = Every 3 Years, W = Written Test, P = Practical Test

44 2 nd Key Issue for OSHA Required Training 2. Develop the training curriculum for each subject

45 ANSI Z490.1 Recommends Develop a written plan showing how the training i will be accomplished, the contents, delivery techniques, attendee participation, ii i etc.

46 ANSI Z490.1 Recommends Assess the competency of the trainers.

47 3 rd Key Issue for OSHA Required Training Develop a plan to assess how well the recipients of the training understood it.

48 Effectiveness of the Training Written tests Oral tests Demonstrations Supervisory observations Followup competency demonstrations

49 OSHA Has Cited Employers for Not Following the Guidance in ANSI Z490.1

50 Let s Review My Suggestion for the Top 5 Most Overlooked Training Requirements

51 Top 5 Overlooked Training Requirements 1. Access to Exposure and Medical Records (g) Required Annually What records are available How to get copies Must provide within 15 days

52 Top 5 Overlooked Training Requirements 1. Access to Exposure and Medical Records (g) Required Annually 2. Caution and Danger Signs and Tags (c)

53 Danger and Caution Signs and Tags (c) Danger Signs mean you do not proceed unless you are trained and authorized Caution Signs mean you may proceed but with a heightened sense of awareness

54 Top 5 Overlooked Training Requirements 1. Access to Exposure and Medical Records (g) 2. Caution and Danger Signs and Tags (c) 3. Lockout/Tagout -- All Others (c)(7)(i)(C)

55 Top 5 Overlooked Training Requirements 1. Access to Exposure and Medical Records (g) 2. Caution and Danger Signs and Tags (c) 145(c) 3. Lockout/Tagout All Others (c)(7)(i)(C) 147(c)(7)(i)(C) 4. First Aid (b) The 4 Minute Rule

56 Top 5 Overlooked Training Requirements 1. Access to Exposure and Medical Records (g) 2. Caution and Danger Signs and Tags (c) 3. Lockout/Tagout All Others (c)(7)(i)(C) 4. First Aid (b) The 4 Minute Rule 5. Electrical Safety Work Practices

57 Electrical Safety Work- Practices Applies to Both Qualified and Unqualified Personnel Train Employees to a Level That Each Can Work Safely Around Electricity

58 (b)(1)(ii) NFPA 99 Requires 4 ozs of Receptacle Tension (g)(2)(iii) Flexible Cords Must Have Strain Relief

59 (b)(1)(viii) Light Bulbs Within 8 of the Floor Guarded (g)(1) Proper Clearance in Front of Electrical Panels

60 (b)(2)(i) Faceplate Should Not be Broken (g)(5) Grounding Path Must be Continuous

61 (g)(1)(iv)(A) Flexible Cords Can Not be Used in Lieu of Fixed Wiring (b)(2) Electrical Equipment Used According to Listing or Labeling

62 In Summary Know what the regulations require regarding workplace training Develop a plan to train to a level that, at least, meets OSHA requirements Followup with employees to determine if the training was understood

63 Thank you! David Coble, MS, CSP CTJ Safety Associates

James J Arendas Ph.D.

James J Arendas Ph.D. Safety Program Elements Management Commitment Hazard Identification Hazard Correction Training Hazard Identification Qualified and Competent Persons Identify Hazards in the Workplace