With enough to worry about when it comes to employee safety, what you should not be worrying about is getting cited for violations you didn’t commit. Unfortunately, in the OSHA realm, that has happened just because someone wasn’t keeping very good records. This is particularly true when it comes to training.

OSHA standards require a lot of training. The amount of training required can seem overwhelming – there’s hazard communication, first responder, fork lift, lock-out/tag-out, process safety management, confined space, fire brigades, just to name some standards with a training component. Further complicating things, the frequency of training differs, and not all employees have to be trained on all topics. Another day we’ll discuss some best practices to ensure that all necessary training is done and done correctly. But today we’re focusing on documenting that training. Because if OSHA shows up at your door and asks for your training records, no matter how much training has been done, if you can’t prove it, you could be facing a citation, despite having done it. Here are some examples of how companies document their training.

By documenting the format of the training. Is it done in person? By a trained company employee or by an outside contractor? Or do you show a video? Are there handouts? Keep documentation for how the training is performed with the “written program” for that standard.

By documenting when the training occurred. Was this initial training, or refresher training? Is this periodic refresher training, refresher training due to a change in job function, or refresher training required due to an accident or the employee acting unsafely? Have a master calendar for all scheduled trainings; HazWOPER refresher training is a good example; it’s required annually for each employee, and companies may find it more effective to conduct annual refresher training once a year for all affected employees. It’s a good practice to also make a note in each employee’s file as to when they received training, but it is critical to do so for training that was specific to that employee, such as initial hazard communication training.

By documenting that each particular employee acknowledges receiving training. Sign-in sheets are good for specific training sessions, but not as useful for all-hands health and safety meetings that sometimes include refresher training. While such sign-in sheets prove the employee showed up, we’ve seen situations where the employees clearly didn’t understand that this meeting was “training,” and in all honesty do not believe they were trained on the topic. We prefer “tests” or “quizzes,” signed by the employee with copies in their file and in the training file, that demonstrate that he/she was paying attention, at least at that time.

Don’t let your hard work of ensuring your employees are properly trained be ignored. Document what your training consists of, when you did it, and that your employees were there. You’ll be glad you did when OSHA asks about your training.

Resources:  OSHA’s Training Requirements in OSHA Standards and Training Guidelines.