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Detailed recordkeeping is an essential aspect of any compliant
training program. In addition to simplifying tracking, documenting your
training can assist in determining when refresher or annual training is needed.
Plus, training records are sure to be reviewed during an OSHA inspection to
ensure your organization is in compliance, so it pays to be thorough.
What are OSHA’s requirements for training records?
There is no one OSHA requirement for training records that applies
in all situations. The requirements vary from standard to standard. Many rules
don’t include training record requirements.
Here are some examples of when OSHA does require training records:
The permit-required confined space standard says that training
certifications must include each employee’s name, the signatures or initials of
the trainers, and the dates of training. OSHA doesn’t set a record retention
Under the asbestos standard, employers have to keep training
records for one year beyond an employee’s last date of employment. The standard
doesn’t detail the content of the records.
The bloodborne pathogens standard states that training records
must include the dates of training, the content of the training sessions, the
names and qualifications of trainers, and the names and job titles of those who
received training. You have to keep these records for at least three years.
Make sure you check the training provisions in each applicable
rule to find out if training records are required, what OSHA wants you to
include on the records, and how long OSHA expects you to keep the records.
Even when training records aren’t required, you may want to keep
them anyway as a way to help organize your training program. Consider including
the employee’s name, the date of the training, the name of the trainer, and the
How long do we have to keep training records?
Sometimes a rule will tell you how long to retain the training
records, but more often than not, there is no record retention requirement.
If a rule doesn’t specifically require a record retention time, an
employer could set a policy to retain training records for a certain number of
years or even for a period after employment has ended. This is up to the
Some employers may decide to keep all training records during the
worker’s full period of employment. This would show evidence of a complete
It’s also important to remember to keep your training records up
to date. If OSHA visits, you must be able to produce the record from the
employee’s most recent training.
How do OSHA compliance officers use training records?
The main reason for keeping training records is because OSHA
requires them. But, what does OSHA look for in training records and how does a
compliance officer (inspector) use them during an inspection?
OSHA inspectors will ask to see your training records when the
OSHA rule in question requires you to keep records. They’ll pay attention to
how much trouble it is for you to find the records. This gives them an
indication of how well organized your training program is. When you can produce
the records without delay, you show that your company pays careful attention to
training and takes it seriously.
The inspector will also check how complete your records are.
Incomplete records point to disorganization and may be an indication of an
inconsistent training program.
Aside from training records, perhaps the most important method
OSHA compliance officers use to evaluate your compliance is to ask employees
about the training they’ve received. If workers praise the training program,
you’ll be in good shape. If many employees don’t remember being trained or give
negative feedback, OSHA will likely take a closer look at your:
Safety Training Records: Requirements and
The materials you use to train;
The methods you use to provide training;
The knowledge of your instructors.
How can we use training records?
After you’ve prepared the training records, don’t just leave them
to sit in the file. Training records have several uses during day-to-day
operations. Use your records to:
Help determine when annual refresher training is required.
Keep track of an employee’s qualifications for job assignment. If
you see someone doing a job that requires specialized training, you can easily
check to be certain he’s received that training.
Help you identify workers who have a solid training history and
may be ready to handle more specialized training for jobs with more
You aren’t the only one who wants to know if the training program
is effective. You should be prepared to periodically submit reports to
Respiratory protection rounded out the top five OSHA most
frequently cited violations of fiscal year 2019. The top 10 list is released every
year, and respiratory protection makes frequent appearances. OSHA reported
2,450 violations adding up to $1.5 million in fines. According to OSHA, the
Respiratory Protection Standard (CFR 1910.134) encompasses the control of
occupational diseases caused by breathing contaminated air, and applies to
general industry, shipyards, marine terminals, longshoring, and construction.
All employers (including contractors) have a responsibility to protect the
respiratory health of their employees. In service of this, OSHA requires
employers to implement appropriate engineering control measures (enclosure of
the operation, ventilation, and/or elimination or substitution of less toxic
materials), and/or effective selection and use of respiratory protection
An estimated 5 million workers are required to wear respirators
for protection against inhalation hazards. In addition to immediate dangers, workers
face future damages from the long-term effects of exposure to inhaled hazards,
including cancer. If respirators are being used, the respirators must be
appropriate to whichever hazardous airborne dusts, fogs, fumes, mists, gases,
smokes, sprays, or vapors your employees are encountering (including
oxygen-deficient environments). They must also be fit tested to ensure they are
an appropriate fit to the wearer.
Along with the use of respirators comes a litany of other
requirements including the development and implementation of a written
respiratory protection program overseen by a specific and qualified individual,
medical clearances to determine that an employee can safely wear a respirator,
and procedures for proper use, storage, and maintenance of respirators. This
list is not exhaustive. The development and maintenance of a respiratory
protection program requires research and dedicated time.
Some of the most common violations stem from employers
distributing respirators without having a respiratory protection program in
place. Others happen when companies believe they have executed a program but
have neglected one or more pieces outlined in the standard. One of the most
commonly overlooked aspects of an implemented program is respirator fit
testing. Respirators are not one size fits all and neglecting to have the
respiratory protection devices fitted to the individual employee greatly
reduces respirator effectiveness. All tight-fitting respirators used in the
workplace require annual fit testing. An important word here is “annual.” Fit
testing is not a one-and-done aspect of a respiratory protection program. The
requirements and approved procedures for fit testing are outlined in Appendix
A of the standard.
Other emerging issues may
point to an increase in respiratory protection violations. A decision published
September 11, 2019, by the United States Court of Appeals for the Ninth Circuit
ruled that the Respiratory Protection Standard also requires that employers
adequately evaluate all appropriate respiratory hazards before determining if a
respirator is required and before selecting an appropriate respirator. This
decision has solidified an expanded purview of the standard. The court
concluded that the Respiratory Protection Standard requires employers to
proactively assess potentially harmful atmospheres rather than performing the
evaluation after a determination has been made that respirators are necessary.
This opinion opens the possibility of OSHA making greater use of the
Respiratory Protection Standard in the future to enforce allegedly harmful
airborne contamination that is not addressed by or below a current permissible
exposure limit. Previously, concerns such as this would have been cited under
the General Duty Clause. This ruling along with the continued failings in the
area may spotlight respiratory protection program issues from the regulatory
side. Don’t be a part of the $1.5 million dollars in fines: select and fit test
your respirators appropriately.
September 30, OSHA withdrew its proposal to revoke the ancillary provisions of
the construction and shipyard beryllium standards. The permissible exposure
limit (PEL) and short-term exposure limit (STEL) already have gone into effect,
and the agency will implement the other provisions of the January 9, 2017,
final rule, which will become effective September 30, 2020.
June 27, 2017, OSHA had proposed revoking the ancillary provisions in the
beryllium standards for construction and shipyards, while retaining the PEL of
0.2 micrograms per cubic meter (µg/m3) and the STEL of 2.0 µg/m3. The agency
suggested portions of the standards duplicated other standards and that those
other standards along with the PEL and STEL could adequately protect workers
from beryllium exposures. OSHA asked stakeholders to comment on the proposed
agency’s new position is that there is little or no overlap between other
standards and the construction and shipyard beryllium standards. OSHA now will
allow the ancillary provisions of the standard to take effect in one year.
then will have to comply with the exposure assessment, methods for controlling
exposure, respiratory protection, personal protective clothing and equipment
(PPE), housekeeping, medical surveillance, hazard communication, and
recordkeeping requirements of the January 9, 2017, final rule.
plans to publish a new proposal for the construction and shipyards beryllium
standards, seeking comment on different changes the agency is considering. The
agency expects to propose changes similar to those proposed December 11, 2018
for the general industry beryllium standard.
New thinking on beryllium protections
reviewing comments on the proposed revocations, OSHA decided that construction
and shipyard beryllium standards consisting only of the PEL and STEL would be
insufficient to protect workers. The agency concluded that despite some overlap
with other standards, paragraphs (d) through (n) of the beryllium standards are
necessary to ensure compliance with the PEL and STEL.
came to the following conclusions about the standards’ ancillary provisions:
No other standards duplicate the exposure assessment requirements in the beryllium standards;
The competent person requirement of the construction standard and the regulated area requirement of the shipyard standard are necessary to ensure all affected workers are protected;
Other standards do not provide protection equivalent to those in the methods of compliance requirements of the two beryllium standards;
While the respiratory protection requirements in the beryllium standards duplicate those of other standards for employees engaged in abrasive blasting, protections for other workers are not duplicated elsewhere;
Only the PPE clothing requirements in the beryllium standards cover all affected workers;
The hygiene areas and practices provisions of the two beryllium standards are necessary to ensure workers are not exposed to beryllium dust in eating and drinking areas;
The housekeeping provisions of the beryllium standards do not completely overlap with the housekeeping requirements of other standards;
There are no other standards that would require medical surveillance of beryllium-exposed employees;
The medical removal program requirements of the beryllium standards provide incentive for employees to comply with the medical surveillance program;
The hazard communication provisions of the beryllium standards go beyond requirements of the general hazard communication standard (HCS); and
No other standards duplicate the recordkeeping requirements of the beryllium standard.
The agency decided not to
revoke the ancillary provisions of the January 9, 2017 final rule. OSHA next
will propose other changes to the construction and shipyard standards
consistent with those already proposed for the general industry standard.
Protecting workers from inhalation hazards has been a concern for more than 2,000 years. As far back as the first century, miners used animal bladder skins to protect themselves from inhaling toxic dust. In the present day, protecting workers from hazardous dust, fumes, vapors, and gases is essential to mitigating the risk of contracting respiratory illnesses. For the workers who are exposed, the perfect situation is to eliminate any possible contact between the worker and the hazard. Where they cannot be eliminated, workers need the right level of respiratory protection. Prevention is critical when it comes to respiratory protection. In many cases, workers without proper protection who are exposed to a respiratory hazard will not necessarily show the signs of damage or disease until years later.
Millions of workers across the globe wear tight-fitting
respirators that often serve as a last line of defense against the inhalation
of harmful airborne contaminants on the job. Yet, tens of thousands of deaths
globally are attributed to work-related respiratory diseases every year.
Respirators are frequently used without training or testing, resulting in the
leakage of contaminants into the respirator. A major cause of leakage is poor
fit. Because of this, the issue of respiratory protection remains a topic of
debate and an essential aspect of national and international safety
legislation. If a respirator does not fit well, it will not provide the
protection required; therefore, respirator fit testing is a critical aspect of
workplace safety. People come in all shapes and sizes, so it is unlikely that
any one respirator will fit every user. Fit testing ensures that the respirator
is suitable for the user.
A fit test uses a challenge agent and a specific protocol to
determine the effectiveness of the seal between the user’s face and the
respiratory interface of a specific make, model, and size of a respirator. This
is vital to ensuring that the RPD is performing correctly and offering the user
the maximum level of protection. Many people are unaware of fit testing or may
confuse it with either a user seal check or flow testing. Even those who are
aware of fit testing may be unsure whether it is a requirement for them. Those
who recognize the need to implement fit testing may be uncertain of how to do
so. You might need to try different makes or sizes to find one that fits
without leaking around the seal. The only way you can know if the seal is good
enough is by having a proper fit test. Currently, in many countries, this is
also the only way of meeting legal requirements.
OSHA’s Respiratory Protection standard (1910.134) provides guidance in the
United States on how to implement a respiratory protection program and perform fit
testing of respirators. It spells out the qualifications of a fit-test
operator, specific fit-testing methods and procedures, and requirements for
recordkeeping. The reality is that many people across industries are still not
aware of the standard or its full requirements. Therefore, it is important to
keep respiratory protection on the forefront of safety concerns. Even more
important, we need to emphasize the message that effective respiratory
protection is not simply a matter of providing a respirator and ticking the
performance box, but vitally is about the specific individual using it, the
hazards involved, and the effectiveness of the fit it delivers. Properly
protecting the breathing of workers is essential as the risk of exposure can be