Safety Training Records: Requirements and Recommendations
By Mark Stromme, Senior EHS Editor at J. J. Keller & Associates, Inc.
Detailed recordkeeping is an essential aspect of any compliant training program. In addition to simplifying tracking, documenting your training can assist in determining when refresher or annual training is needed. Plus, training records are sure to be reviewed during an OSHA inspection to ensure your organization is in compliance, so it pays to be thorough.
Read on to learn what needs to be included in your safety training records and — more importantly still — how they can be used to help mitigate risk and drive performance.
What are OSHA’s requirements for training records?
There is no one OSHA requirement for training records that applies in all situations. The requirements vary from standard to standard. Many rules don’t include training record requirements.
Here are some examples of when OSHA does require training records:
- The permit-required confined space standard says that training certifications must include each employee’s name, the signatures or initials of the trainers, and the dates of training. OSHA doesn’t set a record retention time.
- Under the asbestos standard, employers have to keep training records for one year beyond an employee’s last date of employment. The standard doesn’t detail the content of the records.
- The bloodborne pathogens standard states that training records must include the dates of training, the content of the training sessions, the names and qualifications of trainers, and the names and job titles of those who received training. You have to keep these records for at least three years.
Make sure you check the training provisions in each applicable rule to find out if training records are required, what OSHA wants you to include on the records, and how long OSHA expects you to keep the records.
Even when training records aren’t required, you may want to keep them anyway as a way to help organize your training program. Consider including the employee’s name, the date of the training, the name of the trainer, and the topic covered.
How long do we have to keep training records?
Sometimes a rule will tell you how long to retain the training records, but more often than not, there is no record retention requirement.
If a rule doesn’t specifically require a record retention time, an employer could set a policy to retain training records for a certain number of years or even for a period after employment has ended. This is up to the employer.
Some employers may decide to keep all training records during the worker’s full period of employment. This would show evidence of a complete training history.
It’s also important to remember to keep your training records up to date. If OSHA visits, you must be able to produce the record from the employee’s most recent training.
How do OSHA compliance officers use training records?
The main reason for keeping training records is because OSHA requires them. But, what does OSHA look for in training records and how does a compliance officer (inspector) use them during an inspection?
OSHA inspectors will ask to see your training records when the OSHA rule in question requires you to keep records. They’ll pay attention to how much trouble it is for you to find the records. This gives them an indication of how well organized your training program is. When you can produce the records without delay, you show that your company pays careful attention to training and takes it seriously.
The inspector will also check how complete your records are. Incomplete records point to disorganization and may be an indication of an inconsistent training program.
Aside from training records, perhaps the most important method OSHA compliance officers use to evaluate your compliance is to ask employees about the training they’ve received. If workers praise the training program, you’ll be in good shape. If many employees don’t remember being trained or give negative feedback, OSHA will likely take a closer look at your:
- Training records;
- The materials you use to train;
- The methods you use to provide training;
- The knowledge of your instructors.
How can we use training records?
After you’ve prepared the training records, don’t just leave them to sit in the file. Training records have several uses during day-to-day operations. Use your records to:
- Help determine when annual refresher training is required.
- Keep track of an employee’s qualifications for job assignment. If you see someone doing a job that requires specialized training, you can easily check to be certain he’s received that training.
- Help you identify workers who have a solid training history and may be ready to handle more specialized training for jobs with more responsibility.
You aren’t the only one who wants to know if the training program is effective. You should be prepared to periodically submit reports to management on:
- What training has taken place;
- Who’s been trained;
- How much time was devoted to training;
- What training materials are available;
- How well training objectives have been met;
- How training has improved safety;
- What training is planned for the future.
How We Can Help
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