Do You Know What Your OSHA Training Requirements Are?

For the Occupational Safety and Health Administration (OSHA), the most important goal of occupational safety and health training is the long-term reduction of injury and illness among workers. The immediate effectiveness of training is measured through inspections, test scores, surveys, and observing how workers demonstrate the task they have learned. Long-term effectiveness is measured by evaluating worker attitudes toward risk reduction and hazard control, changes in work practices over time among workers who have received training, and changes in reported health and injury rates.
OSHA training rules for the most part are performance-based standards—the workplace must remain free of hazards, but the employer determines exactly how that will be achieved. An employer can use a variety of methods and technologies for training as long as the safety goal is met. Compliance with a performance standard means that training must be effective—all the time.
For those environmental managers who have safety responsibilities as well, here’s a summary of some OSHA training regulations that might apply to you.

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Asbestos Exposure—General Industry
All employees exposed to airborne asbestos at or above the permissible exposure limit (PEL) must be trained before or at the time of initial assignment. Training must cover:

• The health effects associated with asbestos exposure;
• The relationship between smoking and exposure to asbestos producing lung cancer:
• The quantity, location, manner of use, release, and storage of asbestos, and the specific nature of operations that could result in exposure to asbestos;
• The engineering controls and work practices associated with the employee’s job assignment;
• The specific procedures implemented to protect employees from exposure to asbestos, such as appropriate work practices, emergency and cleanup procedures, and personal protective equipment (PPE) to be used;
• The purpose, proper use, and limitations of respirators and protective clothing, if appropriate;
• The purpose and a description of the medical surveillance program;
• The content of this standard, including appendices;
• The names, addresses, and phone numbers of public health organizations that provide information, materials, and/or conduct programs concerning smoking cessation. The employer may distribute the list of such organizations contained in Appendix I to this section to comply with this requirement; and
• The requirements for posting signs and affixing labels and the meaning of the required legends for such signs and labels.

Employees who perform housekeeping duties in areas with asbestos-containing material (ACM) or presumed asbestos-containing material (PACM) are required to attend awareness training that covers health effects of asbestos, locations of ACM and PACM in the building/facility, recognition of ACM and PACM damage and deterioration, requirements in this standard relating to housekeeping, and proper response to fiber release episodes to all employees who perform housekeeping work in areas where ACM and/or PACM are present. Each such employee must be so trained at least once a year.
Asbestos Exposure—Construction
Workers involved in Class I and Class II operations requiring the use of critical barriers and/or negative pressure enclosures must attend training equivalent to the curriculum, training method, and length of the U.S. Environmental Protection Agency (EPA) Model Accreditation Plan (MAP) asbestos abatement workers’ training.
Workers involved in other Class II operations must attend training that covers:

• Methods of recognizing asbestos;
• The health effects associated with asbestos exposure;
• The relationship between smoking and asbestos in producing lung cancer;
• The nature of operations that could result in exposure to asbestos; the importance of necessary protective controls to minimize exposure, including, as applicable, engineering controls, work practices, respirators, housekeeping procedures, hygiene facilities, protective clothing, decontamination procedures, emergency procedures,  waste disposal procedures, and any necessary instruction in the use of these controls and procedures; where Class III and IV work will be or is performed; the contents of EPA 20T-2003, Managing Asbestos in Place July 1990, or its equivalent in content;
• The purpose, proper use, fitting instructions, and limitations of respirators as required by 29 CFR 1910.134;
• The appropriate work practices for performing the asbestos job;
• Medical surveillance program requirements;
• The content of this standard, including appendices;
• The names, addresses, and phone numbers of public health organizations that provide information, materials, and/or conduct programs concerning smoking cessation. The employer may distribute the list of such organizations contained in Appendix J to this section to comply with this requirement; and
• The requirements for posting signs and affixing labels and the meaning of the required legends for such signs and labels.

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Workers involved in Class III and Class IV operations must attend training consistent with EPA requirements for training of school maintenance and custodial staff.
Workers identified as a competent person must complete a training course in all aspects of asbestos removal and handling consistent with EPA MAP for the appropriate level of work (e.g., Class I, II, III, or IV).
According to OSHA regulations, “Competent person means one who is capable of identifying existing and predictable hazards in the surroundings of working conditions which are unsanitary, hazardous, or dangerous to employees, and who has authorization to take prompt corrective measures to eliminate them.”
In tomorrow’s Advisor, we’ll go over more OSHA training requirements that may apply to environmental training, and we’ll showcase a whole library of online environmental training courses ready to use and available now.