Osha training requirements

V
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 does
OSHA have?


  • For General Industry there are over __
    training requirements.
In General Industry there are 59 specific
training 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 specific
training 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 specific
training 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 specific
training 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 specific
training 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 employee's
                                          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. Construction
Industry



  • 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’s
previous 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’s
previous 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 good
enough?


  • 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 good
enough?


  • 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 good
enough?


  • 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
THANK YOU




      ANY QUESTIONS?
Further



  • Newquist.john@dol.gov or
  • johnanewquist@gmail.com
  • Facebook, Linked-In and Twitter –
    johnanewquist
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Osha training requirements

  • 1. OSHA TRAINING REQUIREMENTS Waubonsee Safety Days Conference 2012 John Newquist Assistant Regional Adminstrator March 14, 2012
  • 2. 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?
  • 3. How many training requirements does OSHA have? • For General Industry there are over __ training requirements.
  • 4. In General Industry there are 59 specific training 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
  • 5. In General Industry there are 59 specific training 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
  • 6. In General Industry there are 59 specific training 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
  • 7. In General Industry there are 59 specific training 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
  • 8. In General Industry there are 59 specific training 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
  • 9. 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
  • 10. 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
  • 11. 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 employee's knowledge or use of the energy control procedures.
  • 12. 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.
  • 13. Forklifts • Initially • Every 3 years • Near Miss • Are the operators trained to inspect?
  • 14. 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.
  • 15. 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
  • 16. 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.
  • 17. 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
  • 18. Confined Space  Train before being assigned, when changes occur  Provide advisory training prior to entry of any space  Rescue training is often inadequate!
  • 19. 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.
  • 20. General Industry VS. Construction Industry • The first two standards in Construction are general safety training standards. • Applies to all construction • Those general standards do not exist in General Industry.
  • 21. Can you rely on training from an employee’s previous 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.
  • 22. Can you rely on training from an employee’s previous 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.
  • 23. Is computer web-based training good enough? • 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.
  • 24. Is computer web-based training good enough? • 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.
  • 25. Is computer web-based training good enough? • 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.
  • 26. PUBLICATIONS GOOD REFERENCE BOOKS 2254 Training Requirements in OSHA Standards and Training Guidelines 2209 Small Business Handbook Revised: 2005
  • 27. THANK YOU ANY QUESTIONS?
  • 28. Further • Newquist.john@dol.gov or • johnanewquist@gmail.com • Facebook, Linked-In and Twitter – johnanewquist

Editor's Notes

  1. Employees need to know when work falls within the scope of this program, and employees involved in hot work need to be trained in the hot work requirements. Employees with fire watch responsibility must be trained to understand the inherent hazards of the work site and of the hot work project, and in the use of their fire extinguishing equipment and alarm notification. 29 CFR 1910.252 (a)(2)(iii) Cutters or welders and their supervisors must be suitably trained in the safe operation of their equipment and the safe use of the process. 29 CFR 1910.252 (a)(2)(xiii)