As we are getting ready for the last quarter of 2021 and looking ahead to 2022, making plans, setting safety and business goals, and identifying safety and business objectives for 2022, one item to consider is that of the annual training required by OSHA regulations. We can work in the last quarter of 2021 to get caught up on our annual safety training requirements that may have been postponed from earlier in 2021. Now is a good time to plan for training that will be needed in 2022.
A learning management system (LMS) is an electronic database that identifies and tracks training per job title based on assigned training requirements determined by the database administrator and employer. Or it could be as simple as a spreadsheet listing each training topic and the employees’ names to track most recent training dates. Or it could be a system somewhere in-between.
Short of reading each OSHA regulation and focusing on the training requirements of each regulation that specifically applies to your operations, tasks, hazards, and potential hazards, trying to identify specifically how often the training needs to be conducted, at a minimum, OSHA has a publication titled “Training Requirements in OSHA Standards”, publication number OSHA 2254-09R 2015 which was last updated in 2015.
Once the research is completed, a policy on safety training can be developed and kept updated listing what training will be conducted, the training schedule, instructor qualifications, and identify which employees receive specific safety training based upon their job positions as well as what training all employees receive on an annual basis and what training a new hire receives as part of their orientation.
Per the identified hazards and potential hazards that specifically applies to your operations and employee tasks, some of the common annually required training topics include Bloodborne Pathogens, Fire Extinguisher Use, Hearing Conservation, Respiratory Protection, Access to Medical and Exposure Records, HAZWOPER refresher, Fire Brigades, Mechanical Power Press operator safety, and for specific chemicals such as asbestos and benzene, carcinogens, lead, formaldehyde or other chemicals if there is a potential for exposure above the PEL. This is by no means an exhaustive list so further review will be needed to apply to your specific operations.
Other topics that may need annual training include many safety procedures and more specifically Control of Hazardous Energy (LOTO), permit-required confined space and rescue, excavation safety and rescue, fall hazards and fall protection and rescue, and/or aerial lift operation, to name a few, if the tasks are considered non-routine (not performed on a regular and/or frequent basis).
Some certifications need to be kept current such as FA/CPR/AED which is required every two years and forklift operator which is required every three years.
There are other training requirements for each topic or regulation that OSHA requires including content or topics of the training and some identify instructor qualifications that need to be adhered to ensure compliance. However, there is nothing wrong, in fact it is strongly encouraged, to exceed the OSHA requirements for training of employees on how to prevent themselves and their coworkers from getting injured while performing work.
With this information, one can begin the planning for training in the last quarter of 2021 to get caught up on annual safety training and plan for training that will be needed in 2022.
For more information and/or assistance, contact:
Wayne Vanderhoof CSP, CIT
RJR Safety Inc.