Catching & Correcting OSHA’s Top 10 – Training Requirements

Published On: April 29, 2024

The OSHA Top 10 is a list of the most cited violations in a given fiscal year (October 1 – September 30). Inspectors are on high alert for these violations and are likely to issue citations for them. OSHA violations begin at $16,131 per violation per day. If that violation was to occur again in a 5-year period, the citation jumps to $161,323. By being diligent with OSHA requirements, you can protect your workers and your bottom line. A common theme among the OSHA Top 10 is training and related documentation.

Types of Training

According to OSHA, training should be provided “in a manner that employees understand,” which includes the language, vocabulary, and mode of instruction. Employees must be trained in the tasks, situations, tools, and hazards that they will encounter while working. OSHA recommends training every 365 days, but training must be performed as often as needed for safe operations.

In most cases, there are OSHA requirements on a periodic basis, but there are a few circumstances in which retraining is required, such as an incident. Training can be offered in person or online, based on the employers’ preference.

Toolbox Talks

Toolbox talks are short training sessions that serve as a refresher on training. This helps to keep information fresh and front-of-mind for employees.

New Employee Training

New employees should be trained in all regulations related to their job.

Periodic Training

Includes when new processes are added, or a workplace change occurs which exposes the employee to new hazards.

Annual Training

Annual training is classified as retraining on things that were originally trained during orientation.

Incident-Based Retraining

In an incident, or if employee performance suggests prior training was not understood, retraining is required.

Documentation

In addition to observing employees’ safety skills, OSHA inspectors will also ask to review training documents, including curriculum and attendance. Curriculum is any presentation, video and handouts used in training. Attendance is monitored on a sign-in sheet where all employees being trained sign their name to prove they were there. All training records must be kept for at least three years from the date on which the training took place. However, it is recommended to keep training documentation for the length of employment.

2023 Top 10 Training Requirements

Hazard Communication – Annual or with a process change

Powered Industrial Trucks – Every 3 years or with incident.

Lockout/Tagout – Annual training for all users and periodic inspections for authorized users

Personal Protective Equipment – Annually, with a process change, or with incident

Conclusion

Training is commonality with all citations on the OSHA Top 10 list. This means that most citations could have been avoided with proper employee training and documentation. Lack of training can lead not only to worker injuries, but also costly fines from OSHA.

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