Preventing Serious Injuries at Work

Frequently asked questions about safety training and OSHA compliance.

Contributed by: J. J. Keller®

A lot of Occupational Safety and Health Administration (OSHA) regulations specify training requirements, while others simply imply a need for training. It’s important for employers and safety instructors to understand their operations, and rely on their knowledge, experience and education to train employees, and prevent serious injuries at work.

The answers to the following frequently asked questions should help your organization avoid the most common OSHA violations:

What types of courses are beneficial for all safety training instructors?

OSHA does not always require safety training instructors to complete specific training courses. However, the regulations often do describe the knowledge the trainer must possess, which is typically gained through education, experience, or a combination of both.

Knowledge and experience alone do not make a good trainer. The instructor must be able to convey information effectively, in an engaging manner, and be able to answer questions from trainees. Instructors benefit from training on how to develop and present material, how to understand audiences, and how to appeal to different learning styles.

What types of training and experience are required to train powered industrial truck operators?

The powered industrial truck regulation (1910.178) says that training “shall be conducted by persons who have the knowledge, training, and experience to train powered industrial truck operators and evaluate their competence.” OSHA clarified that the instructor must have experience with the equipment (truck type) or attachment in order to provide training.

Can OSHA question the background of safety instructors?

The bloodborne pathogen standard at 1910.1030 says the trainer “shall be knowledgeable in the subject matter covered by the elements contained in the training program as it relates to the workplace that the training will address.” OSHA clarified that the trainer need not be a health care professional, but if there are deficiencies in the quality of the training, OSHA may question the trainer’s background.

Which regulations require training?

A lot of regulations require training, while others imply a need for training. For instance, Emergency Action Plans under 1910.38 requires employers to develop “procedures to be followed by employees.” although the word ‘training’ doesn’t appear in that section.

What training Is employers required to provide?

The training each employer must provide depends on its operations. For example, if employees use hazardous chemicals, they probably need hazard communication training. Each employer must determine which regulations apply, then determine if the regulation requires training.

Which regulations require annual refresher training?

Quite a few regulations require annual training. Among them are Occupational Noise Exposure, HAZWOPER, Respiratory Protection, Fire Brigades, Portable Fire Extinguishers, and Bloodborne Pathogens.

In addition, some standards require evaluations, like three-year evaluations of powered industrial truck operators. Some regulations don’t specifically mention refresher training, but do require reviews, such as periodic inspections under lockout tagout. Even when a refresher isn’t required, providing it may be a good idea. If employees do not retain information and cannot answer questions about the training they received (possibly several years ago), your company could be cited for failure to provide training.

Regulation 1910.178 specifies that training “shall be conducted by persons who have the knowledge, training, and experience to train powered industrial truck operators and evaluate their competence.” © Stock Rocket – stock.adobe.com

WHAT IS THE MOST COMMON OSHA VIOLATION?

The OSHA top 10 violation list doesn’t change much year to year, but you might not realize that most citations are issued to small employers. For example, Hazard Communication gets cited nearly 4,000 times per year, but more than half get issued to employers with fewer than 20 employees.

What are the top four OSHA violations for small employers?

Lockout/tagout and machine guarding top the list in both total penalties and number of OSHA citations. These violations create the potential for serious injury, resulting in higher fines. Specific paragraphs cited are not available, but experience should help you determine where to look in your own programs to prevent these violations.

Number three (by penalty amount) is process safety management, which isn’t surprising given the potential seriousness of an incident.

Powered industrial trucks comes in fourth. These heavy vehicles create substantial hazards for pedestrians (and operators). If OSHA responds to a forklift-related injury or observes an operator doing something unsafe, the agency doesn’t give the driver a ticket; instead, OSHA will cite the company.

What is covered by the “General Duty Clause”?

The “General Duty Clause” ranks high on the list, and covers “hazards that are causing or likely to cause death or serious physical harm,” so higher penalties would be expected. Maintaining exit routes is also high on the list, since a blocked exit door or aisle is extremely dangerous — and those violations are easily spotted. Reporting serious injuries also made the list, likely because these incidents were not reported within the required time frame.

Using the list above should help focus your safety efforts on the most common violations, and based on the penalty amounts, these are also the violations most likely to cause serious injuries. WMHS

J.J. Keller® offers world class world-class EHS and workplace safety solutions.The company’s SAFETY MANAGEMENT SUITE with RegSense makes it easy to review the regulations, guidance, and frequently asked questions about a regulation. Topics are sorted alphabetically, and each topic contains a variety of resources needed for compliance. Learn more at www.jjkellersafety.com.