OSHA Required Training Presented By David F. Coble, MS, CSP Coble, Taylor & Jones Safety Associates www.ctjsafety.com t
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
Other Resources The Safety Professionals Handbook Management Applications Section 4 Safety and Health Training and ASSE Webinar Provided on April 14, 2009
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
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
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
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
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
Compressed Gas Assoc. Pamphlet P-1 Requires Training for Those Who Handle and Use Gas Cylinders 1910.101(b)
Another Example, The Owner s Manual of the Welding Machine Requires Training 1910.254(d)(6)
OSHA General Industry Vs. Construction Differences Scaffolds Construction has a training requirement 1926.454 General Industry does not The hazard is the same
General Industry Vs. Construction Differences Fall Protection Construction has a training requirement 1926.503 General Industry does not The hazard is the same.
General Industry vs Construction Differences Construction has Generic Training Requirements (1926.21) General Industry Does Not!
Many Standards Require Only Initial Training i Ladder Usage and Inspection [1926.1060] Danger Signs and Tags [1910.145(c)] 145(c)] Overhead and Gantry Crane Operators [1910.179(b)(8)] 179(b)(8)] Sling Inspections [1910.184(d)] Welding, Burning and Cutting [1910.252,.253 and.254 and 1926.350(d) and.351(d)]
Some Standards Require Initial Training and Repeat Training if There are Problems or Changes Emergency Action Plans [1910.38(f)] Personal Protective Equipment [1910.132(f)(3)] )] Permit Confined Spaces [1910.146(g)(2)] Powered Industrial Trucks [1910.178(l)(4)] 178(l)(4)] Fall Protection [1926.503(c)] For Example
Arrow indicates where the employee was pinned beneath the overhead canopy.
Was the floor of this trailer inspected before entry?
Could training for this worker be deficient? i
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?
A Few Standards Require Evaluation of Training and Then Followup If There are Problems Personal Protective Equipment [1910.132(f)(3)] Confined Spaces Rescue [1910.146(k)(1)(i)] Wheel Rims [1910.177(c)(3)] For Example
Multi-Piece and Single Piece Rim Wheels 29 CFR 1910. 177
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
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
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
Multi-Piece and Single Rim Wheels Protection Restraining Device For Single or Multi-piece Barrier For Single Piece Only
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 Confined Spaces 1910.146(g)(4) Fall Protection 1926.503(b)(1) Building Powered Platforms 1910.66(i)(1)(v) ) Process Safety Management 1910.119(g)(3) Personal Protective Equipment 1910.132(f)(4) Lockout 1910.147(c)(7)(iv) Powered Industrial Trucks 1910.178(l)(6) 178(l)(6) Telecommunications 1910.268(c) Bloodborne Pathogens 1910.1030(h)(2)
Typical Certification Record CTJ Safety Associates FALL PROTECTION TRAINING ROSTER Certification of Training in Accordance with 1926.503(b) Page 1 of 1 Date of Training Employee Name Work Location Initials Trainer s Signature: Date:
Requirement for Qualified Trainer About 12 Requirements Hazwoper 1910.120(e)(3)(i) - (iii) Fall Protection 1926.503(a)(2) Building Powered Platforms 1910.66(i)(1)(iii) Scaffolds 1926.451(a)(1) and (b)(1) Mobile Cranes 1910.180 (h)(3)(xii) Respirator Program Administrator 1910.134 (c)(3) Emergency Response 1910.120(q)(7) Powered Industrial Trucks 1910.178(l)(2)(iii) Overhead Cranes 1910.179(n)(3)(ix) Bloodborne Pathogens 1910.1030(g)(2)(viii)
39 OSHA Standards Require Initial and Annual Training Hearing Conservation [1910.95(k)(2)] Respirator Users [1910.134(k)(5)] 134(k)(5)] Fire Extinguisher Users [1910.157(g)] Access to Exposure and Medical Records [1910.1020(g)(1) and 1926.33] Bloodborne Pathogens [1910.1030(g)(2)]
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)
Different Levels of Training Would Be Expected 1910.332(a) 1910.269(a)(2)
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
Inspecting Abrasive Wheels 1910.215(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
In other words, there are quite a few regulatory required training topics! This must be managed. OSHA s Recommended Training Management System?...
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.
The ANSI/ASSE Z490.1 (2009) standard was developed to improve the consistency and quality of training development, delivery, evaluation and management.
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.
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
Needs Assessment Use the Following Documents OSHA Standards State and Federal Consensus Standards Manufacturer s Instructions and Manuals Local Codes and Laws Association Guides
Content What They Need to Know 1. Needs assessment 2. Develop a matrix or chart of required training
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
2 nd Key Issue for OSHA Required Training 2. Develop the training curriculum for each subject
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.
ANSI Z490.1 Recommends Assess the competency of the trainers.
3 rd Key Issue for OSHA Required Training Develop a plan to assess how well the recipients of the training understood it.
Effectiveness of the Training Written tests Oral tests Demonstrations Supervisory observations Followup competency demonstrations
OSHA Has Cited Employers for Not Following the Guidance in ANSI Z490.1
Let s Review My Suggestion for the Top 5 Most Overlooked Training Requirements
Top 5 Overlooked Training Requirements 1. Access to Exposure and Medical Records 1910.1020(g) Required Annually What records are available How to get copies Must provide within 15 days
Top 5 Overlooked Training Requirements 1. Access to Exposure and Medical Records 1910.1020(g) Required Annually 2. Caution and Danger Signs and Tags 1910.145(c)
Danger and Caution Signs and Tags 1910.145(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
Top 5 Overlooked Training Requirements 1. Access to Exposure and Medical Records 1910.1020(g) 2. Caution and Danger Signs and Tags 1910.145(c) 3. Lockout/Tagout -- All Others 1910.147(c)(7)(i)(C)
Top 5 Overlooked Training Requirements 1. Access to Exposure and Medical Records 1910.1020(g) 2. Caution and Danger Signs and Tags 1910.145(c) 145(c) 3. Lockout/Tagout All Others 1910.147(c)(7)(i)(C) 147(c)(7)(i)(C) 4. First Aid 1910.151(b) The 4 Minute Rule
Top 5 Overlooked Training Requirements 1. Access to Exposure and Medical Records 1910.1020(g) 2. Caution and Danger Signs and Tags 1910.145(c) 3. Lockout/Tagout All Others 1910.147(c)(7)(i)(C) 4. First Aid 1910.151(b) The 4 Minute Rule 5. Electrical Safety Work Practices 1910.332
Electrical Safety Work- Practices Applies to Both Qualified and Unqualified Personnel Train Employees to a Level That Each Can Work Safely Around Electricity
1910.303(b)(1)(ii) NFPA 99 Requires 4 ozs of Receptacle Tension 1910.305(g)(2)(iii) Flexible Cords Must Have Strain Relief
1910.303(b)(1)(viii) Light Bulbs Within 8 of the Floor Guarded 1910.303(g)(1) Proper Clearance in Front of Electrical Panels
1910.305(b)(2)(i) Faceplate Should Not be Broken 1910.304(g)(5) Grounding Path Must be Continuous
1910.305(g)(1)(iv)(A) Flexible Cords Can Not be Used in Lieu of Fixed Wiring 1910.303(b)(2) Electrical Equipment Used According to Listing or Labeling
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
Thank you! David Coble, MS, CSP CTJ Safety Associates www.ctjsafety.com