Resolve to meet OSHA’s annual training requirements this year

It’s a best practice to conduct annual safety training, but which of OSHA’s regulations actually require it? While over 70 of OSHA’s general industry regulations have training requirements, not all of them have an annual requirement. Following are the ones that do:

• Access to Employee Exposure and Medical Records — 1910.1020
• Bloodborne Pathogens —1910.1030
• Fire Brigades —1910.156
• Fixed Extinguishing Systems —1910.160
• Grain Handling Facilities —1910.272
• Hazardous Waste Operations and Emergency Response (HAZWOPER) —1910.120
• Mechanical Power Presses —1910.217
• Occupational Noise —1910.95
• Permit-required Confined Space —1910.146
• Portable Fire Extinguishers —1910.157
• Respiratory protection —1910.134
• Chemical-specific regulations in 1910 Subpart Z. Note: The only chemical-specific Subpart Z regulations that do not require annual training are:
  • 1910.1002—Coal Tar Pitch Volatiles,
  • 1910.1026—Hexavalent Chromium,
  • 1910.1052—Methylene Chloride, and
  • 1910.1096—Ionizing Radiation (However, the employer must advise employees of their ionizing radiation monitoring results annually.)

The Process Safety Management standard (1910.119) requires training every three years, and the Powered Industrial Trucks standard requires forklift drivers to be evaluated at least every three years — the standard outlines conditions that require refresher forklift operator training at 1910.178(l)(4).

Remember that training on a particular topic depends on whether it applies to work your employees are performing. As an example, if employees aren’t exposed to noise levels at or above an 8-hour time weighted average (TWA), you’re not required to train on occupational noise exposure.

Less frequent training requirements

Other general industry standards require retraining “as needed,” when there are changes in the workplace that would affect previous training (such as a new chemical hazard, like flammability), or when certain other circumstances indicate that retraining is needed (i.e., employees aren’t putting into practice what they learned in training). Consider questioning employees as you walk through the facility and observing whether they’re using safe work practices. This can help determine if refresher training is needed.

It’s a best practice to conduct refresher training, even if a regulation doesn’t require it. From a safety perspective, remember that if employees can’t answer questions from an OSHA inspector, your company can be cited for lack of training, even if you have documentation showing that the employee attended training.

If OSHA doesn’t require refresher training, you don’t have to go through an entire program. You can keep the sessions brief and touch on key points. Consider covering different material each time to help keep the content fresh. Using Hazard Communication (HazCom) as an example, you may talk about HazCom-style labels one month and discuss Safety Data Sheets the next.