osha required trainingosha required training -...

OSHA Required TrainingOSHA Required Training

Presented ByDavid F. Coble, MS, CSP

Coble, Taylor & JonesCoble, Taylor & Jones Safety Associates

tj f twww.ctjsafety.com

David F Coble MS CSPDavid 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 HandbookManagement ApplicationsManagement Applications

Section 4 Safety and Health Training and

ASSE Webinar Provided SS Web a ov dedon April 14, 2009

GoalsGoals• Review OSHA Required Training q g

Found in 1910 and 1926• Discuss Certification Records• Discuss Certification Records,

Trainer Requirements and Subject MMatter

• Review OSHA Expectations FoundReview OSHA Expectations Found in OSHA Letters of Interpretation and My Own Experienceand My Own Experience

OSHA Required Training

Number of OSHA Training and Inspection Requirementsand Inspection Requirements

• 190 General Industry Training Rules190 General Industry Training Rules• 140 Construction Training Rules• 250 General Industry Inspection

Rules• 150 Construction Inspection Rules

For a Free Copy ofFor a Free Copy of CTJ Safety Associates’

Ch kli tChecklists…OSHA Required Training for

General IndustryOSHA Required Training forOSHA 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

• Ladders• Scaffolds• Aerial Lifts

• Bloodborne P th

• Scaffolds• Signs and Tags

Pathogens• Confined Spaces

• Slings• Welding

• …g

Nearly 200 DocumentsNearly 200 Documents Incorporated by Reference

• Professional Organization’s Documents (API CGA etc )Documents (API, CGA, etc.)

• Welding Manuals• Underwriter’s Lab Standards• Consensus Standards (ANSI NFPA• Consensus Standards (ANSI, NFPA,

etc.)• For Example…

Compressed Gas Assoc. Pamphlet P-1R i T i i f Th WhRequires Training for Those Who

Handle and Use Gas CylindersHandle and Use Gas Cylinders

1910.101(b)

Another Example, The Owner’s Manual of the Welding MachineManual of the Welding Machine

Requires Training

1910.254(d)(6)

OSHA General Industry Vs.OSHA General Industry Vs. Construction Differences

• Scaffolds Constr ction has aConstruction has a

training requirement 1926 4541926.454

General Industry does not

The hazard is the same

General Industry Vs. Construction Differences

• Fall Protection• Fall ProtectionConstruction has a

training requirement 1926.503

General Industry does not

The hazard is the same.

General Industry vs C i DiffConstruction Differences

• Construction has Generic TrainingConstruction has Generic Training Requirements (1926.21)

• General Industry Does Not!• General Industry Does Not!

Many Standards Require Only I iti l T i iInitial Training

• Ladder Usage and Inspection [1926.1060]• Danger Signs and Tags [1910 145(c)]Danger Signs and Tags [1910.145(c)]• Overhead and Gantry Crane Operators

[1910 179(b)(8)][1910.179(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 InitialSome Standards Require Initial Training and Repeat Training if There

P bl Chare Problems or Changes

• Emergency Action Plans [1910.38(f)]• Personal Protective Equipment [1910.132(f)(3)]q p [ ( )( )]• Permit Confined Spaces [1910.146(g)(2)]• Powered Industrial Trucks [1910 178(l)(4)]• Powered Industrial Trucks [1910.178(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 i t d b f t ?inspected before entry?

Could training for this k b d fi i t?worker be deficient?

Could training for this k b d fi i t?worker be deficient?

What if??What if??- Moving vehicles are present?- The weed eater throws a rock at him?

H t bl t?- 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 ProblemsFollowup If There are Problems

• Personal Protective Equipment q p[1910.132(f)(3)]

• Confined Spaces Rescue [1910.146(k)(1)(i)]Confined Spaces Rescue [1910.146(k)(1)(i)]• Wheel Rims [1910.177(c)(3)]

F E lFor Example…

Multi-Piece and Single Piece Rim WheelsRim Wheels29 CFR 1910 17729 CFR 1910. 177

Multi-Piece and Single Rim Wheelsg

• Standard Includes:– Large TrucksLarge Trucks– Buses – TrailersTrailers– Off-road Machines

• Does Not Include:Does Not Include:– Automobile Tires– Light Truck Tires – Designated “LT”Light Truck Tires Designated LT

Mechanic Killed by Exploding Tire –OS AC #0 CA00NIOSH FACE Report #05CA007

• May 25, 2005• Apprentice mechanic checking airApprentice mechanic checking air

pressure on a military wheel• Stood over the tire and used a wrench to• Stood over the tire and used a wrench to

adjust the bolts on the flangeTi l d d d kill d h i• Tire exploded and killed mechanic

M lti Pi d Si l Pi RiMulti-Piece and Single Piece Rims

• Multi-Piece: Inflate only if 80% inflated and using remote control inflation gequipment, and out of trajectory

• Single Piece: Inflate only if all l f ll i hlug nuts fully tight

Multi-Piece and Single Rim Wheelsg

• Protection– Restraining Device g

• For Single or Multi-piece

– Barrier• For Single Piece

OnlyOnly

Written Certification of Training

• There are about a dozen standards that require a written certification record of qthe training.

• This must include the employee’s nameThis must include the employee s name, the signature of the trainer and the dates of the training.of the training.

• For example…

Written Certification Record of Training About 25Record of Training – About 25

Requirements

• Confined Spaces• Personal Protective

Equipment• Confined Spaces 1910.146(g)(4)

• Fall Protection

Equipment 1910.132(f)(4)

• Lockout 1926.503(b)(1)

• Building Powered Pl tf 1910 66(i)(1)( )

1910.147(c)(7)(iv) • Powered Industrial

Trucks 1910 178(l)(6)Platforms 1910.66(i)(1)(v) • Process Safety

Management

Trucks 1910.178(l)(6) • Telecommunications

1910.268(c) Management 1910.119(g)(3) • Bloodborne Pathogens

1910.1030(h)(2)

Typical Certification RecordCTJ Safety Associates FALL PROTECTION TRAINING ROSTER

Page 1 of 1 Date of Training

Certification of Training in Accordance with 1926.503(b)Employee Name Work Location Initials

Trainer’s Signature: Date:

Requirement for Qualified Trainer –About 12 Requirements

• Hazwoper 1910.120(e)(3)(i) - (iii)F ll P t ti

• Respirator Program Administrator 1910 134 ( )(3)• Fall Protection

1926.503(a)(2)• Building Powered

1910.134 (c)(3)• Emergency Response

1910.120(q)(7)Building Powered Platforms 1910.66(i)(1)(iii)S ff

1910.120(q)(7)• Powered Industrial

Trucks 1910.178(l)(2)(iii)• Scaffolds

1926.451(a)(1) and (b)(1)• Mobile Cranes

• Overhead Cranes 1910.179(n)(3)(ix)

• Bloodborne Pathogens• Mobile Cranes 1910.180 (h)(3)(xii)

• 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)]Respirator Users [1910.134(k)(5)]• Fire Extinguisher Users [1910.157(g)]

A E d M di l R d• 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 ComputerOSHA has expectations for Computer

Based training (OSHA Letter of Interpretation to Nancy Wickler datedInterpretation to Nancy Wickler dated January 15, 1999)

• Keep a record of all training indefinitely• Keep a record of all training indefinitely• Train to a level so that the employee can

d th j b f l (i l t i l kdo the job safely (i.e., electrical work practices) …

Different 1910.332(a)

1910 269(a)(2)Levels of Training 1910.269(a)(2)Would Be Expected

Training Fundamentals• Annual means every 365 days to OSHA• OSHA has expectations for ComputerOSHA has expectations for Computer

Based training• Keep a record of all training indefinitely• Keep a record of all training indefinitely• Train to a level so that the employee can

d th j b f l (i l t i l kdo the job safely (i.e., electrical work practices)

• Your employees can not do effective inspections until they ff p yhave been trained; for example…

Inspecting Abrasive Wheels1910 215(d)(1)1910.215(d)(1)

• Before mounting:i l l f dinspect closely for damage perform sound- or ring-test to ensure free from cracks /to ensure free from cracks / defects

• To test:tap wheel gently with a light non metalliclight, non-metallic instrumentif wheel sounds cracked or dead, do not use it because it could fly apart

In other words, there areIn other words, there are quite a few regulatory

required training topics! This must be managedThis must be managed.

OSHA’s Recommended Training Management

System?System?...

OSHA’s Voluntary TrainingOSHA s Voluntary Training Guidelines Issued July 27, 1984

• (1) determine whether a worksite problem can be solved by training; (2) determine y g; ( )what training, if any, is needed; (3) identify goals and objectives for the training;(4) g j g;( )design leaning activities; (5) conduct training; (6) determine the effectiveness of g; ( )the training; and (7) revise the training program based on feedback from p gemployees, supervisors, and others.

The ANSI/ASSE Z490.1 (2009) standard was developed tostandard was developed to

improve the consistency and quality of training

development deliverydevelopment, delivery, evaluation and management.g

1st Key Issue for Effective Training Content – What They Need to Know

1. Do a Needs Assessment1. Do a Needs Assessment

• Use the CTJ Safety Checklists on• Use the CTJ Safety Checklists on required training as a starting point, ii.e. …

1st Key Issue for OSHA Required Training – What They Need to Know

1. Do a Needs Assessment1. Do a Needs Assessment

• Use the CTJ Safety Checklists on• Use the CTJ Safety Checklists on required training as a starting point

• Walkthrough audits, interviews, incident reports, safety meeting p , f y gminutes

• And the following• And, the following…

Needs Assessment – Use theNeeds Assessment Use the Following Documents…

• OSHA Standards – State and FederalFederal

• Consensus Standards• Manufacturer’s Instructions and

M lManuals• Local Codes and LawsLocal Codes and Laws• Association Guides

Content – What They Need to Know

1. Needs assessment

2. Develop a matrix or chart of required trainingof required training…

Training Topics Details** Mechanics Helpers Machinists

A i l Lift H 3 W √ √Aerial Lifts H, 3, W √ √

Asbestos C, A, W √ √

Bloodborne Pathogens

CB, A, W √ √ √

√Burning/Cutting

H, I, P √

Chemicals CB, T, I, W √ √ √Confined Spaces

C, H, A, P √ √

Emergencies C, A, W √ √ √Emergencies C, A, W √ √ √Etc. From A to Z

** H = Hands On T = Tool Box C = Classroom CB =** 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

2nd Key Issue for OSHA Required TrainingTraining

2. Develop the training i l f h bj tcurriculum for each subject

ANSI Z490.1 Recommends…

Develop a written plan showing h th t i i ill bhow the training will be

accomplished, the contents, p , ,delivery techniques, attendee

i i iparticipation, etc.

ANSI Z490.1 Recommends…

Assess the competency of the t itrainers.

3rd Key Issue for OSHA Required TrainingOSHA Required Training

Develop a plan to assess howDevelop a plan to assess how well the recipients of the p ftraining understood it.

Effectiveness of the Training

• Written tests• Oral testsOral tests• Demonstrations

S i b i• Supervisory observations• Followup competency demonstrations

OSHA Has Cited Employers for NotEmployers for Not

Following the Guidance inGuidance in ANSI Z490.1

Let’s Review My Suggestion for thethe

Top 5 Most Overlooked Training p gRequirements

Top 5 Overlooked TrainingTop 5 Overlooked Training Requirements

1. Access to Exposure and Medical Records 1910.1020(g) –Records 1910.1020(g) Required AnnuallyWh t d il bl• What records are available

• How to get copiesow to get cop es• Must provide within 15 days

Top 5 Overlooked TrainingTop 5 Overlooked Training Requirements

1. Access to Exposure and Medical Records 1910.1020(g) – Required (g) qAnnually

2 Caution and Danger Signs and2. Caution and Danger Signs and Tags 1910.145(c)

Danger and Caution Signs andDanger and Caution Signs and Tags – 1910.145(c)

• Danger Signs mean you g g ydo not proceed unless you are trained and yauthorized

• Caution Signs mean youCaution Signs mean you may proceed but with a heightened sense ofheightened sense of awareness

Top 5 Overlooked TrainingTop 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)1910.147(c)(7)(i)(C)

Top 5 Overlooked TrainingTop 5 Overlooked Training Requirements

1. Access to Exposure and Medical Records 1910.1020(g)(g)

2. Caution and Danger Signs and Tags 1910 145(c)1910.145(c)

3. Lockout/Tagout All Others 1910 147(c)(7)(i)(C)1910.147(c)(7)(i)(C)

4. First Aid 1910.151(b) The 4 Minute Rule

Top 5 Overlooked TrainingTop 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 Others3. 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 332Practices 1910.332

Electrical Safety Work-Practices Applies to BothPractices Applies to Both Qualified and Unqualified

Personnel –Train Employees to a LevelTrain Employees to a Level

That Each Can Work Safely yAround Electricity

1910.303(b)(1)(ii) NFPA 99 Requires 4 ozs of Receptacle Tension

1910.305(g)(2)(iii)1910.305(g)(2)(iii) Flexible Cords

Must Have StrainMust Have Strain Relief

1910.303(b)(1)(viii) Light Bulbs WithinLight Bulbs Within

8’ of the Floor GuardedGuarded

1910.303(g)(1) Proper Clearance in Front of

Electrical Panels

1910 305(b)(2)(i)1910.305(b)(2)(i) Faceplate Should Not be

BrokenBroken

1910.304(g)(5) Grounding PathGrounding Path

Must be Continuous

1910.305(g)(1)(iv)(A) Flexible Cords Can NotFlexible Cords Can Not be Used in Lieu of Fixed

WiringWiring

1910.303(b)(2) Electrical EquipmentElectrical Equipment

Used According to Listing or LabelingListing or Labeling

In Summary…

• Know what the regulations require regarding orkplace trainingregarding 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

Th k !Thank you!

David Coble, MS, CSPDavid Coble, MS, CSPCTJ Safety Associatesy

www.ctjsafety.com