OSHA TRAINING REQUIREMENTS Waubonsee Safety Days Conference 2012 John Newquist Assistant Regional Adminstrator March 14, 2012
TOPICS • Training requirements • Ten training area often found inadequate • General Industry (GI) vs. Construction Industry training requirements • Training provided from an employee’s previous employer? • Computer web-based training good enough?
How many training requirements doesOSHA have? • For General Industry there are over __ training requirements.
In General Industry there are 59 specifictraining requirements. • 1910.38: Emergency Action • 1910.110: Storage and Plan Handling of Liquefied • 1910.66: Powered Platforms Petroleum Gases for Building Maintenance • 1910.119: Process Safety Operations Training Management of Highly • 1910.94: Dip Tanks –Personal Hazardous Chemicals; Protection; Inspection, Operators, contractors and Maintenance and Installation mechanical integrity • 1910.95: Hearing Protection; • 1910.120: Hazardous Waste Training Program Operations and Emergency • 1910.106: Flammable and Response; Cleanup Workers, Combustible liquids New Technology Program, Emergency Responders • 1910.109: Explosive and • 1910.132: Personal Protective Blasting Agents; Bulk Equipment Delivery and Mixing Vehicles
In General Industry there are 59 specifictraining requirements. • 1910.134: Respiratory • 1910.151: Medical Services Protection, Respiratory and First-Aid Protection for M • 1910.155: Fire Protection Tuberculosis • 1910.156: Fire Brigades, and • 1910.142: Temporary Labor training and Education Camps • 1910.157: Portable Fire • 1910.145: Specifications for Extinguishers Accident Prevention Signs • 1910.160: Fixed and Tags Extinguishing Systems • 1910.146: Permit Required • 1910.164: Fire Detecting Confined Spaces Systems • 1910.147: The Control of • 1910.165: Employee Alarm Hazardous Energy (LO/TO), Systems LO/TO devices removed, and outside personnel
In General Industry there are 59 specifictraining requirements. • 1910.177: Servicing of Multi- • 1910.252: Welding, Cutting, Piece and Single-Piece Rim and Brazing Wheels • 1910.253: Oxygen – Fuel Gas • 1910.178: Powered Industrial Welding and Cutting Trucks • 1910.254: Arc Welding and • 1910.179: Overhead cranes, Cutting moving the load • 1910.255:Arc Welding and • 1910.180: Crawler Cutting locomotives and Truck • 1910.255: Resistance Cranes Welding • 1910.217: Mechanical Power • 1910.261: Pulp, Paper and Presses, operators and Paperboard Mills maintenance personnel • 1910.264: Laundry • 1910.218: Forging Machines Machinery and Operating Rules
In General Industry there are 59 specifictraining requirements. • 1910.266: Logging • 1910.332: Safety Related Work- • 1910.268: Telecommunications, Practices derrick trucks, cable fault • 1910.410: Qualifications of Dive locating, guarding manholes, Team joint power and • 1910.1001: Asbestos telecommunication manholes, • 1910.1017: Vinyl Chloride and tree trimming-electrical • 1910.1018: Inorganic Arsenic hazards • • 1910.1025: Lead 1910.269: Electric Power Generation, Transmission, and • 1926.1026: Chromium VI Distribution • 1910.1027: Cadmium • 1910.272: Grain Handling • 1910.1028: Benzene Facilities, Entry into Bins, Silos • 1910.1029: Coke Oven Emissions and tanks, and contractors • 1910.1030: Bloodborne Pathogens
In General Industry there are 59 specifictraining requirements. • 1910.1043: Cotton Dust • 1910.1200: Hazard • 1910.1044: 1,2-Dibromo-3- Communication Chloro-propane • 1910.1450: Occupational • 1910.1045: Acrylonitrile Exposure to Hazardous (Vinyl Cyanide) Chemicals in Laboratories • 1910.1047: Ethylene Oxide • 1910.1048: Formaldehyde • 1910.1050: 4,4’ Methylenedianiline • 1910.1096: Ionizing Radiation Testing and Posting
Injury Prevention Basics• Management Leadership • These principles are• Employee Participation adopted and recognized by…• Hazard Identification, – 2100 VPP Companies Prevention and Control – 1600 SHARPs – 1926.20, 1926.21• Education and Training – 1910.119 – ANSI Z9.10• Program Evaluation and – OHSAS 18001 Improvement – States AR, CA, LA, HI,• Communication and MN, MT NV, NH, NY, OR, WA coordination on multi- employer sites
Hazard Communication • Trained initially and • Location of program, when new chemical list of chemical, and introduced MSDS • OSHA standard • Detection of chemical covered • Hazards of chemical • Operations in their • Protection measures work area where • Emergency chemical is used procedures • Labeling system used
Lockout • Employees who must be trained • No annual requirement, but initially Retraining when.. – Authorized • A change in job assignments. – Affected • A change in machines, equipment, – Others - Contractors or processes that present a new • hazard. Retraining • A change in the energy control • Certify training procedures. • Periodic inspections reveal that there are deviations in the energy control procedure. • The employer believes that there are deviations from, or inadequacies in, the employees knowledge or use of the energy control procedures.
PPE • Communicate PPE selection decisions to each affected employee • The employer shall provide training to each employee who is required by this section to use PPE. Each such employee shall be trained to know at least the following: • When PPE is necessary; • What PPE is necessary; How to properly don, doff, adjust, and wear PPE; • The limitations of the PPE; and • The proper care, maintenance, useful life and disposal of the PPE. • Each affected employee shall demonstrate an understanding of the training specified in paragraph 1910.132(f)(1) of this section, and the ability to use PPE properly, before being allowed to perform work requiring the use of PPE.
Forklifts • Initially • Every 3 years • Near Miss • Are the operators trained to inspect?
Hot Works • Train personnel on hot work policies/procedures, proper use and calibration of combustible gas detectors, safety equipment, fire watch responsibility, and job specific hazards and Cutters or welders and their controls in a language supervisors must be understood by the suitably trained in the safe workforce. operation of their equipment and the safe use of the process.
Respirators • Training must be provided prior to use, unless acceptable training has been provided by another employer within the past 12 months • Retraining is required annually, and when: – changes in the workplace or type of respirator render previous training obsolete – there are inadequacies in the employee’s knowledge or use – any other situation arises in which retraining appears necessary • The basic advisory information in Appendix D must be provided to employees who wear respirators when use is not required by this standard or by the employer
Hearing Conservation • Applies if over 85 dbA • 1910.95 • The employer shall provide training in the use and care of all hearing protectors provided to employees. • The training program shall be repeated annually • Train on effects of noise, access to the OSHA standard Proper insertion will affect the and where it is posted. quality of sound reduction.
Electrical Arc Flash • Removing or installing circuit breakers or fuses • Voltage testing • Working on control circuits when energized parts exposed • Applying safety grounds • Racking circuit breakers • Racking starters • Removing bolted covers
Confined Space Train before being assigned, when changes occur Provide advisory training prior to entry of any space Rescue training is often inadequate!
Boilers • Over a hundred boiler explosions and fires in the last ten years. • These are pressure vessels. • People assigned to operate and maintain the boilers have little or no boiler safety training.
General Industry VS. ConstructionIndustry • The first two standards in Construction are general safety training standards. • Applies to all construction • Those general standards do not exist in General Industry.
Can you rely on training from an employee’sprevious employer? • It depends what was covered. • Training should be specific to the current employer’s policies, programs and the hazards that the employee will encounter.
Can you rely on training from an employee’sprevious employer? • Some training standards that requires an employer to certify the training and maintain the records. • Some standards that require refresher training when there are changes in the employees working conditions.
Is computer web-based training goodenough? • No, in GI, be careful of standards such as 1910.178(l)(2)(ii) that requires practical (demonstration) training. • In Construction 1926.1427 (effective Nov 2014) it will requires practical training as well.
Is computer web-based training goodenough? • Computer web-based training can and is a good tool to assist with safety and health training but should not become the only method of training for OSHA standards. • There are some OSHA standards where computer web-based training would be good, such as Hazcom, Emergency Action, and Fire Prevention.
Is computer web-based training goodenough? • Some of the pitfalls of computer web-base training can be: – Can the employee read including read English well enough to understand the program – If the program stays the same from year to year, considering the changes made in the facility – Is there any interaction between the employee and the trainer to ensure the employee understand the training per Dr. Michaels memo.
PUBLICATIONS GOOD REFERENCE BOOKS 2254 Training Requirements in OSHA Standards and Training Guidelines 2209 Small Business Handbook Revised: 2005
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