Training Requirements in Construction

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Training has become a strong focus recently in the construction industry to reduce accidents and injuries. Studies have proven that training not only provides a more competent workforce, but also a safer work environment. Another motivating factor is fines from the result of OSHA citations. In the 2017 top 10 list, 4,174 of the citations were training related.  If those were all compiled into one standard, it would have been the 3rd most frequently cited standard in 2017. But, when is training required? When is refresher training required? What documentation is needed? What resources are available?

When is Training
Most people are familiar with, and already have training programs for, aerial lifts, rigging & signaling, and powered industrial trucks. But, just to name a few others, hand & power tools, stairways and ladders, occupational noise exposure, fire protection, and employee emergency action plans also require a written training program.

What about earth moving equipment, golf carts, and other equipment with no direct OSHA standard? 1926.20(b)(4) states that “the employer shall permit only those employees qualified by training or experience to operate equipment and machinery.” This proof of competency is accomplished through the creation of a written training program. The focus of this program is the recognition and avoidance of hazards and unsafe conditions related to the task. Elements needed in the program include the type of instruction, practical training, and evaluation methods used. Each employee that could be assigned that task or exposed to that hazard must be trained, if not that could be considered a separate violation. It is the responsibility of the employer to document and prove competency. Depending on the type of training, toolbox talks can also be used.

When is Refresher Training Required
Refresher training can be broken down into three categories: OSHA driven, accident/injury driven, and company driven. The following OSHA standards require annual training refreshers: bloodborne pathogens, confined space rescue team, hazardous waste operations and emergency response (HAZWOPER), occupational noise exposure, and respiratory protection. Toxic and hazardous chemicals all require at least initial training; the following hazardous chemicals require annual training: acrylonitrile, asbestos, benzene, butadiene, cadmium, carcinogens, coke oven emissions, ethylene oxide, formaldehyde, inorganic arsenic, lead, methylenedianiline, & vinyl chloride. First Aid/CPR requires refresher training every 2 years. Process safety management and powered industrial trucks require refresher training every 3 years. Aerial lift refresher should occur every 4 years.

Refresher training can also be required in the event of an accident, injury, or near miss. This category includes: when an operator of a vehicle or equipment is observed using it in an unsafe manner, the operator has received an evaluation that reveals the operator is not operating safely, the operator is assigned a different vehicle or equipment, or as workplace conditions change that affect safe operation of the vehicle or equipment.

Finally, the company has the ability to implement their own refresher training dates, as long as they minimally meet the OSHA standards.

Training Documentation Required
The documentation needed for training varies for each standard. But, at a minimum the following information is required. (1) Name and signature of the trainer; (2) Name of the employee (signature is not required); (3) Date of training; (4) Subject of training; (5) Proof of competency and date of evaluation. This proof of competency can be a written test, practical evaluation sheet, or a combination of both. Another critical piece of documentation is the availability of the records. The employer is required to make the training records available to employees and upon request to the Assistant Secretary and the Director for examination and copying. These training documents must be produced within 4 hours of being requested. The storage of records should be maintained for a minimum of 3 years after the date of training. Only the most current training records need to be stored. Failure to document employee safety training can lead to OSHA citations and fines in the event of an OSHA inspection or in an accident investigation.
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Resources Available
Training resource information can also be broken into 4 categories: manufacturer, Insurance agencies, suppliers/dealers, and regulatory agencies. Manufacturers’ create manuals and other safety information that explains safe operating standards and training requirements for the equipment or machinery. OSHA relies on these manuals in the absence of written standards when writing citations. Insurance agencies can provide written training programs and even training in some cases. Equipment and tool dealers also can provide written programs and competent person training. Regulatory agencies, such as OSHA or ANSI, produces a multitude of great resources and publications. The best resources for OSHA training requirements is OSHA 2254 publication “Training Requirements in OSHA Standards.” This publication is the compilation of all OSHA standards in general industry, maritime, construction, agriculture, and federal employee programs that have training requirements. 

Reposted from constructionexec.com, May 18, 2018, a publication of Associated Builders and Contractors. Copyright 2018. All rights reserved.
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