OSHA's focus on training compliance is growing

J.J. Keller & Associates

There is no single OSHArule for training – employee trainingis a requirement in several different OSHA standards. In a recent speech, Secretary of Labor Hilda Solis announced a number of new worker training initiatives that will be implemented by OSHA.

According to Solis, OSHA currently requires that training provisions under its standards be provided in a language or a form that the workers can understand. The agency further requires that its compliance officers verify that workers have received the training required by OSHA standards.

However, effective April 28th, OSHA compliance officers will check not only that the training has been provided, but that it was provided in a format that the workers being trained can understand.

This new effort stems from an incident in which a worker was crushed to death in a machine she was cleaning. She had not been trained on how to clean the machinery safely and had not been given the manual to read because the employer stated that the employee could not speak or read English.

"This defies logic and is reprehensible!" stated Solis.

In CPL 2-2.38(D)(1998), OSHA says "If the employees receive job instructions in a language other than English, then training and information ... will also need to be conducted in a foreign language."

In a 1999 letter of interpretation OSHA states "instruction ... must be tailored to the employees' language and education ..."

Employees must be instructed in both a language and vocabulary that they can understand. For example, if an employee does not speak or comprehend English, instruction must be provided in a language the employee can understand. Similarly, if the employee's vocabulary is limited, the training must account for that limitation.

These new training record initiatives will help to protect workers from hazards, Solis says. She is also calling on all workers to speak up about workplace violations.

How Does Your Training Measure Up?
To be in compliance then, employees must be provided information in a manner that they can understand. OSHA says that the definition of training is "providing employees with information that will allow work to be performed in a safe and healthful manner." How do you do that?

Check OSHA's Training Requirements at a Glancein KellerOnline. This document explains who must be trained, when they must be trained, and any training recordkeeping requirements.

You will find useful training materials in the Interactive Toolsarea – including classroom-based programsand interactive, online courses. You will find a wide-range of training topics – in both English and Spanish.

KOL also provides training videos in the Learning Center. There are 51 training videos available on 13 different workplace safety topics, as well as a variety of posters, cartoons, clip art, photos, and other materials which you can use to stimulate and challenge your students during your training sessions.

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