Q. Are there any regulations on how often you must have safety meetings?
A. Federal OSHA has no regulation that states how often you must have safety meetings. There are regulations that mandate training on a schedule such as Bloodborne Pathogens (29 CFR 1910.1030) training, which is required annually.
Other general industry standards that require annual training include:
- Asbestos—29 CFR 1910.1001
- Exposure and Medical Records—29 CFR 1910.1020
- Fire Brigades—29 CFR 1910.156 (quarterly training required for interior structural firefighters)
- Fire Extinguishers—29 CFR 1910.157
- Fixed Fire Extinguisher Systems—29 CFR 1910.160
- Grain Handling—29 CFR 1910.272
- HAZWOPER—29 CFR 1910.120
- Machine Guarding—29 CFR 1910.217 and 218
- Noise—29 CFR 1910.95
- Respiratory Protection—29 CFR 1910.134
- Toxic Substances—29 CFR 1910.1003, 1017,1018, 1025 to 1029, 1043, 1045to 1048, 1050
Then there are two standards that require training every 3 years: Process Safety Management (29 CFR 1910.119) and Powered Industrial Trucks (29 CFR 1910.178).
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Q. Can PPE training (safety glasses and ear plugs) be taught online through the company intranet or does it have to have a live instructor?
A. PPE training for safety glasses and ear plugs can be taught online through the company intranet, as long as the employee can demonstrate the proper use of PPE. In other words, once the PPE training is completed you must verify that the employee knows how to use it.
Q. What’s the relationship between OSHA, EPA, and DOT training requirements?
A. The EPA, OSHA, and DOT each have separate training rules, but there is often overlap among the various training requirements. For example, an employer may have workers managing hazardous waste and have the same workers preparing hazardous materials for transportation. In this situation, EPA’s hazardous waste rules, OSHA’s Hazardous Waste Operations and Emergency Response (HAZWOPER) requirements, and DOT’s hazardous materials training standards would all apply. Therefore, it is important to be familiar with each agency’s training rules. In some cases, OSHA and EPA have separate training requirements for the same operation, process, or substance. It can be difficult to determine which rule applies in a specific situation. Check with the agencies if you have further questions.
To contact OSHA with questions, go to http://www.osha.gov/html/Feed_Back.html for information about e-mail, phone, and written inquiries, or contact your OSHA area office. For contact information about area offices, go to http://www.osha.gov/html/RAmap.html.
To contact the EPA with questions, go to http://www.epa.gov/epahome/hotline.htm for a list of phone numbers and e-mail addresses for specific environmental issues.
To contact DOT with questions, go to https://ntl.custhelp.com/app/ask.
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Q. When is confined space training required?
A. According to 29 CFR 1910.146(g), employees who work in confined spaces must be trained on the safe performance of their duties before initial assignment, before a change in assigned duties, upon a change in operations that presents a new hazard, when there are deviations in procedures, and when employee knowledge is inadequate.
Q. The only medical records we keep are those for initial employment and what is required for workers’ comp for employees who have workplace accidents. Must we do the annual training listed under 29 CFR 1910.1020?
A. 29 CFR 1910.1020 applies to employees exposed to hazardous substances and does not apply to work situations where employees are only exposed to safety hazards such as slips, trips, cuts, etc., or onetime first aid. So, annual training is not necessary unless your employees are exposed to hazardous substances.
If employees are exposed to hazardous substances, then the training requirements of 29 CFR 1910.1020(g) do apply, and workers must be trained upon initial employment and informed about the existence, location, and availability of all exposure and medical records. You must also identify personnel responsible for maintaining and providing access to the records and explain employee rights of access to records. Annual refresher training is required.
In tomorrow’s Advisor, we’ll look at two more safety training Q & As—plus discuss an online training resource that includes an extensive library of workplace safety training sessions.