How to Document Compliance with Training Requirements

Date First Published on SafetySmart Compliance: April 14th, 2012
Topics: Safety Training |

Companies that deliberately cut corners on safety training deserve no sympathy if they get socked with an OSHA citation. Unfortunately, it’s not just the “bad guys” who get into trouble. Companies, like yours that make a conscious effort to train still end up getting cited for training violations. These companies learn a painful but important lesson: It’s not enough just to train your workers; you must also be able to prove that you do. And that’s not all. In many cases, you need to take steps to verify that workers understood the training you provided. Here’s how to document your training efforts.

Click here for Model Training Log you can use to document training.

The Importance of Documentation

I’ll bet this isn’t the first time somebody has told you to document your training efforts. But here’s a demonstration of why documentation is so important just in case you didn’t take the message to heart. It’s a tale of 2 companies.

Company Fined Because It Can’t Document Training

During a routine inspection, an OSHA investigator smelled sewer gases in a trench and discovered that none of the workers knew they should check for poisonous gases or determine if the air in the trench had enough oxygen. The contractor in charge of the excavation was fined $2,500 for failure to train workers how to recognize and avoid unsafe conditions. The contractor appealed, claiming that he had trained the workers. But he didn’t have the documents to prove it. So the Occupational Safety Health Review Commission (OSHRC) upheld the fine [Sec’y of Labor v. J. Mess Plumbing Co., Inc., OSHRC Docket No. 04-0197].

Company Avoids Fines Because It Can Document Training

An OSHA inspector interviewed the victim of a serious workplace incident in Michigan. The victim said the company had never trained her and that she didn’t know about the hazard. But the company had written records showing that training sessions were held and that the victim had attended them. When she saw her signature on the attendance sheet, the victim suddenly “remembered” that she had been trained, after all, the company’s safety director relates. No citations were issued.

What to Do to Document Training

Proving training is not something you can do at the last moment after an OSHA inspector shows up. “Trying to pull together the training records is very difficult after the fact,” warns a Georgia lawyer. You need a proactive strategy to document key information about each training session. A training log should be a big part of that strategy. Let’s talk about how to create one.

In addition to documenting compliance with training requirements, keeping a training log can help you:

Cut Injuries: Having a written record showing the training each worker has received and when enables you to check if workers are qualified to do the jobs you assign them. This is important because it’s easy to lose track of what jobs an individual worker has been trained to perform. You can also use the logs to diagnose hazards or patterns of injury more effectively. For example, if a series of incident occurs, you may discover by analyzing the training logs that all of the victims were trained by the same foreman and that you need to relieve the foreman of further training duties.

Comply With Retraining Requirements: OSHA requires you to retrain each worker periodically (typically no less than once a year). You must also retrain workers before they begin a new job if their new duties expose them to hazards for which they haven’t received the appropriate training. Employers may forget about retraining or lose track of when they last provided the worker training. Training logs can help avoid these mistakes because they show when initial training was provided and when retraining is due.

Document Certification: Some OSHA standards, such as Personal Protective Equipment and Powered Platforms, require verification of training. There has to be a written certification of training for each worker. To prepare this certification, you must have a written record of who was trained, on what date and by whom. This is where training logs can make a huge difference. Even though the actual certification goes to the worker, you need to keep a record of the information it’s based on for your files.

How to Create a Training Log

Click here for Model Training Log you can use to document training.

A training log doesn’t have to be elaborate. But it does have to capture the right information. Your training log should include:

  • The worker’s name;
  • The subject of each training session;
  • The dates of each training session;
  • The dates of each retraining session;
  • Signatures or initials of each trainer; and
  • Whether the worker received a certification required by the OSHA standards.

How to Use Your Training Log

Once you create the log, have your supervisors fill out a separate training form for each of their workers. Each time they create or update a training form, they should keep the original and send a copy to:

  • The safety director, to keep in a central employee safety training file; and
  • The personnel department, to keep in the worker’s personnel file.

This should ensure that your logs are complete and on hand when and if an OSHA inspector demands to see them.

Conclusion

Safety training is a fundamental requirement of occupational health and safety laws. But providing safety training isn’t enough to ensure compliance. You must also be able to document your training efforts. And even that is not enough. Employers must be able to prove not simply that they delivered training to their workers but that they took steps to verify its effectiveness.