OSHA employee training - Instructor certification?

OSHA generally sets broad goals and objectives. They provide very few specifics on how to get there. In the workplace, you will find programs that are virtually impossible to follow and others that are very simple. I subscribe to the "Keep It Simple Stupid?" concept. My goal is to show you how to eliminate as much of the "red tape" as possible while, at the same time, ensuring that the workplace is in compliance with OSHA.

This feature will address instructor qualifications. Do you need some type of certification from OSHA before you can provide safety training to your own employees on General Industry Standards? Before I answer that, let us define those standards as they are referenced in the Code of Federal Regulations (CFR).

Virtually every business is subject to these standards:

  • Hazard Communications 29 CFR 1910.1200
  • Emergency Action Plan 20 CFR 1910.38
  • Fire Safety 29 CFR 1910.39
  • Exit Routes 29 CFR 1910.34 through 1910.37
  • Walking/Working Surfaces 29 CFR 1910. Subpart D
  • Medical and First Aid 29 CFR 1910.151

Your business may also be subject to these standards:

  • Machine Guarding 29 CFR Subpart O
  • Lockout/Tagout 29 CFR 1910.147
  • Electrical 29 CFR Subpart S
  • Personal Protective Equipment (PPE) 29 CFR 1910. Subpart I
  • Respirators 29 CFR 1910.134
  • Noise 29 CFR 1910.95
  • Confined Spaces 29 CFR 1910.146
  • Bloodborne Pathogens 29 CFR 1910.1030
  • Powered Industrial Trucks CFR 1910.178
  • Formaldehyde CFR 1910.1200

This is not a complete list of General Industry Standards. In addition, there is Section 5. This is known as the General Duty Clause. It requires employers to provide employees with a safe workplace. Should something fall through the cracks of the General Industry Standards, they can still cite you using the authority granted under Section 5.

The above standards require the employee to be advised on hazards in their work area and trained in how to minimize their exposure and work safely. Some of the standards require annual renewal training as well.

The focus question is Who can conduct this training?? Does one have to be certified? Can an employee be used to train employees? Can you just show a video? Can you use the Internet? Can it be done on the phone? How thorough must it be? Are there minimum time requirements? What kind of records are needed to document that the required training was done?

For the purposes of this discussion, please consider these remarks limited to the following standards:

1910.1030: Bloodborne Pathogen Standard & Safe Needlestick Act of 2001

1910.1048: Formaldehyde Standard

1910.1200: Hazard Communication Standard

1910.134: Respiratory Protection Standard

1910.132: Personal Protective Equipment Standard

These are the primary hazards that require initial training. Several require annual renewal training as well.

Now, to the question about the instructor needing some sort of OSHA certification; the short answer is no. While each of these standards has their own unique wording regarding instructors, the wording used in bloodborne pathogens is typical.

1910.1030 (g) (2) (ix) (A)
The person conducting the training shall be knowledgeable in the subject matter covered by the elements contained in the training program as it relates to the workplace that the training will address.

In the training section of each standard, you will find the required topics that must be addressed as part of an employee?s initial training. There are no minimum time periods, but from a practical point of view, it will take some time to review the required areas.

For example, Hazard Communications Training requires a section by section review of a Material Safety Data Sheet, a review of physical and health hazards and target organ effects. That takes time, and we haven?t even addressed labeling, PPE, and specific hazards.

Annual renewal training gives an instructor more latitude in what areas to cover. You can vary the training each year. You can hold multiple training sessions. Just remember to do the training every twelve months.

Additional Requirements for the Instructor

Training is required to be interactive. The participants must have an opportunity to ask questions. They can request certain issues be expanded on or clarified. This is an important area. At Compliance Plus, we often get calls from safety officers at funeral homes using our Plug and Play Training CD?s. They will check that someone will be at our office if they have a question they cannot answer. We will give them a back-line phone number so they are always able to reach us. By law, questions must be answered without undo delay, such as you would have using an email response.

There are no stipulations against the employer using the Internet, a PowerPoint presentation, or even a telephone or satellite broadcast to train employees as long as the employees are allowed to ask questions and have them answered without delay.

A Caveat

Doing your own training rather than relying on an outside consultant can have its drawbacks. This happened recently with one of our funeral home clients. In the past, we went to his place every year. When we developed a PowerPoint presentation that also did the training, he opted to go with it as an alternative to having us come to him. It was less expensive. I reminded him that his annual training was soon due and not to forget it. I ran into my customer at a meeting a few months later and ask how the training went. He had forgotten to do it.

The Bottom Line

OSHA is just as comfortable having a knowledgeable embalmer train other embalmers as they are an OSHA expert. In fact, the former has some advantages over the other, as they are more knowledgeable about the hazards of their particular workplace. However, it is essential that this person be familiar with the mandatory topics and with safe practices for working around known hazards.

There are a number of reasons to use consultants to conduct or help you conduct employee safety training. Just know that the lack of having a card that certifies you as a qualified OSHA instructor is not one of them. None of the five standards listed above require it.

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KISS Compliance Network Inc. dba Compliance Plus
Gary Finch is a licensed funeral director and embalmer in Texas. He founded KISS Compliance Network, Inc. in 1991. The company does business as Compliance Plus. They write funeral home safety programs and develop Plug and Play PowerPoint Training CD?s for funeral homes across the country. All of their representatives are dual licensed and have 30 years experience in the funeral industry.
(800) 950-1101
email: gfinch@kisscompliance.net