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Documenting the Training

Remember, as far as OSHA is concerned... If it isn't in writing, it didn't get done!

Protect the Employee and the Employer

As a member of your employer's safety staff, it's not only your responsibility to help protect employees, it's also your obligation to help protect the employer. One of the best ways to do that is to ensure strong safety training documentation.

It's not just a good idea for the employer to keep complete and accurate records of all safety and health training, it's required by more than 100 OSHA standards, and it's also recommended by ANSI Z490.1-2016.

Records can provide evidence of the employer's good faith effort to comply with OSHA standards. Strong documentation can also help the employer defend against claims of negligence. Documentation can also supply an answer to one of the first questions an accident investigator will ask: "Was the injured employee adequately trained to do the job?"

1. One of the best ways you can help to protect your employer is to ensure _____.

a. zero tolerance
b. safety committee control
c. strong documentation
d. OSHA avoidance

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Attendance Rosters

roster
Sample Attendance Roster
(Click to enlarge)

As we learned before, if your training or safety meeting presents general information related to safety it's most likely considered safety "instruction." Since we do not need to evaluate employee performance to determine the ability to perform hazardous tasks or procedures, it may be perfectly fine to use a standard attendance roster to document safety instruction. An attendance roster may include the following information:

  • Date
  • Subject
  • Names attendees
  • Other identifying information

2. Which of the following is the minimum requirement to document general safety instruction?

a. Attendance rosters
b. Verbal confirmation
c. Supervisor certification
d. Written exam scores

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Formal Certification of Training

When safety training requires employees to demonstrate knowledge, skills, and abilities (KSAs) in performing hazardous procedures or using safe practices, an attendance roster may not be legally sufficient to document the training.

Technical safety training should include formal written certification that KSAs have been achieved. Certification of training usually involves issuing a certificate of competency or qualification. According to ANSI Z490.1-2016, Section 7.4, Issuing Certificates, recommended certification of training should include:

  • Trainee's name
  • Course title
  • Date, location and hours of instruction
  • Statement that the trainee has successfully completed the course
  • Name and address of training provider
  • Date periodic refresher training is due (if required) or expiration date
  • A unique trainee identification number
  • The level of training or type of certificate awarded
  • Any other information required by regulation
  • Number of credits (CECs, CEUs, etc), if issued. Make sure employees have met all requirements for credits.

To make your documentation stronger, you may want to consider including the following information:

  • Trainee statement that he/she was provided opportunity to ask questions and perform procedures and practices.
  • Trainer statement that trainees, through testing, demonstrated adequate knowledge.
  • Trainer statement that measurement (testing) of knowledge and skills was conducted and that trainees met or exceeded required levels of performance
  • Trainee statement of intent to comply with the procedures, practices, policies, and rules.
  • Trainee statement of understanding that failure to comply may result in discipline
  • A list or description of the specific subject(s) being trained. Describe the safety procedures, practices, policies, rules addressed in training.
  • A list or description of the specific procedures practiced in the learning environment.
  • Certification - a place for trainee and trainer signatures

Click on the link to see a sample training certification.

3. Technical "how-to" safety training should include a formal certification that _____.

a. students completed a written exam
b. training has been completed
c. KSAs have been achieved
d. students completed training

Check your Work

Read the material in each section to find the correct answer to each quiz question. After answering all the questions, click on the "Check Quiz Answers" button to grade your quiz and see your score. You will receive a message if you forgot to answer one of the questions. After clicking the button, the questions you missed will be listed below. You can correct any missed questions and check your answers again.

Final Exam
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