Safety Training Records: Requirements and Recommendations

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 time.
  • 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 topic covered.

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 employer.

Some employers may decide to keep all training records during the worker’s full period of employment. This would show evidence of a complete training history.

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 Recommendations

  • Training records;
  • 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 responsibility.

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 management on:

  • What training has taken place;
  • Who’s been trained;
  • How much time was devoted to training;
  • What training materials are available;
  • How well training objectives have been met;
  • How training has improved safety;
  • What training is planned for the future.

Inhalation Hazard Protection for 5 Million Workers

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 devices.

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.

OSHA moving forward with Obama-era beryllium rules

On 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.

On 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 revocations.

The 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.

Employers 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.

OSHA 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

After 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.

OSHA 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.

Hidden Dangers Causing Respiratory Illnesses

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 life threatening.

Valley fever

Coccidioidomycosis or cocci (pronounced “coxy”), the fungus that causes valley fever, thrives in dry, undisturbed soil. It becomes airborne when that soil is disturbed — whether it’s by dirt bikes, construction crews, or farmers putting in new fruit or nut orchards. It can travel on the wind as far as 75 miles away. Years of climate change-fueled drought and a 240 percent increase in dust storms appear to have led to a swift rise in the number of people diagnosed with the illness across the Southwest.

In California, rates of new cases rose 10 percent between 2017 and 2018, according to the California Department of Public Health, at what will likely be a sizable cost to the state. The state budgeted $8 million for valley fever research in 2018, and about $3 million will go toward the expansion of the Valley Fever Institute at Kern Medical hospital. Three new laws address valley fever reporting, testing, and education in the state. In 2011, California spent approximately $2.2 billion in valley fever-related hospital expenses.

Getting an accurate count of the number of people affected by valley fever is a challenge because the majority of those who are infected never know they have it. However, new cases are especially concentrated in the San Joaquin Valley, home to the farms that produce two-thirds of the nation’s fruit and nuts and one third of its vegetables. The region is also home to the two cities with the worst particle pollution in the U.S. and most of the state’s farmworkers.

In 2017, the Centers for Disease Control and Prevention said 14,364 cases of valley fever were reported nationally, but that “tens of thousands more illnesses likely occur and may be misdiagnosed because many patients are not tested for valley fever.” On average, there were approximately 200 deaths associated with the illness each year in the U.S. from 1999 to 2016.

Dr. Royce Johnson, director of the Valley Fever Institute and professor of medicine at the University of California, Los Angeles, said 60 percent of valley fever cases are misinterpreted as the flu and go undiagnosed. Johnson, who has been working with valley fever patients for more than 40 years, says the remaining 40 percent tend to experience symptoms that are similar to and often confused with a serious case of pneumonia. From there, a small percentage — around 1 percent of the total people infected — see the disease spread to other parts of the body, including the brain and the skin.

will usually think this is the worst illness they’ve ever had,” Johnson said, adding that the symptoms can get quite a lot worse in cases where it spreads. Patients are treated for between three and 12 months and then tracked for an additional two years to make sure the disease doesn’t come back or spread.

“A lot of people don’t understand how manifold and complicated valley fever can be,” Johnson said.

The infection is not passed from person to person, but epidemiologists are still trying to determine what exactly puts people at risk, aside from simply being outside, said Stephen McCurdy, who serves as a professor in the Department of Epidemiology and Preventive Medicine at the University of California, Davis, which created the California Center for Valley Fever in 2016.

Farms in California’s Central Valley, such as this pistachio orchard, contribute to arid conditions and dust problems, according to scientists. Nirma Hasty / NBC News

Immune function is one key factor, putting pregnant women, some diabetics, people with HIV, the elderly, and those who are on immunosuppressant drugs or have had organ transplants at elevated risk. Race appears to be another factor, McCurdy said. “It seems that darker-skinned people are more likely if they contract valley fever to get a more severe case of it. In the majority of cases, people knock it back themselves [like a typical flu]. People with darker skin seem to be less able to do that.”

It’s not entirely clear just why that is. “I’m sure it’s related to whatever genetic resources those groups have compared to others,” he said.

According to a study by the California Health and Human Services Agency, African Americans and Hispanics in California are more likely to be hospitalized with valley fever than whites.

“A contributing factor to this finding may be the large populations of Hispanics living and working in the endemic region counties of California,” wrote the study’s authors, who added that the connection between race and risk for the disease “is not well understood and may be attributable to variations in genetic susceptibility.” Another challenge with gathering data, said Carol Sipan, a public health lecturer at the University of California, Merced, is the fact that, “many

would go back to Mexico if they got really sick.” In Mexico, she added, valley fever is not a reportable disease.