6 Easy Steps to OSHAⓇ Employee Safety Training Records Requirements
The Occupational Safety and Health Administration (OSHAⓇ) was created in 1970 to assure worker health and safety by setting and enforcing standards and providing training, outreach, education, and compliance assistance. For those companies operating within the United States, it is mandatory to comply with all OSHAⓇ regulations.
Under the Occupational Safety and Health Act, employers are responsible for providing a safe and healthy workplace. To avoid injuries and work related deaths as well as citations and substantial fines, your company must comply with OSHAⓇ requirements, including those that require you to document specialized employee training.
Step-by-Step Guide to OSHAⓇ Training Record Management
Step 1: Know the difference between documentation and certification.
Documentation is the storage of necessary details for things like industrial hygiene
reports, Safety Data Sheets, and inspection records.
Certification applies mostly to training and contains information like who, when, where, and what.
Certificates only need to contain minimal information to note that training was done.
Required information includes:
- Name of the employee (signature is not required)
- Name and signature of the trainer
- Date of training
- Subject of training
- Proof of competency (results of some kind of evaluation, such as a test or demonstration of ability) and date of evaluation
Step 2: Understand what training is required in the OSHAⓇ documentation regulations.
These documents must be WRITTEN and FILED
While there are many OSHAⓇ standards that require employee training, not all require that you document the training. However, here are the main standards that do require certification documentation of training:
- Hazardous waste operations (HAZWOPER)*
- Process safety management (PSM)
- Personal protective equipment (PPE)
- Permit-required confined spaces
- Powered platforms
- Electric power generation, transmission, and distribution
- Power press operators
- Powered industrial trucks
- Fall protection
- Respiratory protection
* Required to be an authorized third-party certification.
**Employers need to certify each employee in first aid and CPR as well.
It is important to note that training documents must be WRITTEN and FILED, and some training standards may require more than just documentation. For example, the respiratory protection standard requires written documentation of medical evaluations, fit testing, and training. For more details about each standard, OSHAⓇ lists training requirements in their publication Training Requirements in OSHA Standards.
Step 3: Keep training records up to date and easily available.
Do not take the responsibility for documenting safety training lightly. OSHAⓇ has the right to ask for safety-related records at any time. Therefore, records should be kept current, accurate, legible, and dated—not only for OSHAⓇ, but also for the employer’s benefit. Documentation can also help lend support in case of liability/worker compensation claims.
Step 4: Securely store your documents
It’s not enough to just be able to produce your safety training records on demand any time OSHAⓇ requests them; your documents must also be secured. It doesn’t matter if you use an electronic record management system for your employee safety training records or a paper-based system for recordkeeping. You must have a means of securing them.
If you use computer-assisted training programs, taking advantage of a learning management system (LMS) is not only a great way to secure and document certification, but is also a great way to track employee training and evaluations.
Step 5: Know how long to keep safety training records
The specific length of time that records should be kept may be mandated by legislation or regulations. But as a general rule, training records should be kept for as long as an employee works for an organization. It is also a good idea to keep them for a few more years after the employee leaves, as there could be a chance of them coming back or rehiring them.
Step 6: Have required documentation for your contractors
Lastly, you should have copies of the required documentation from contractors. Just because they’re not regular employees doesn’t mean that you’re not required to ensure their records are in order.
Should you keep records even if they are not required by OSHA?
Yes! You should keep records for all aspects of formal safety training, even when it’s not required. This could include records of future training dates and summaries of training content. These records are useful because they can help assess future training needs and keep track of employee progression through different programs.
Become OSHAⓇ Compliant for Employee Training Recordkeeping
Training workers to do their jobs safely is an investment that pays back over and over again in fewer injuries and illnesses, better morale, lower insurance premiums, and more. But when incidents occur, you need to have records of all safety and health training.
Otherwise, you won’t have the proof required to answer incident investigators when they ask, “Did the employee receive adequate training to do the job?”