What is OSHA Compliance Training?
Health and safety training is a critical piece of OSHA's mission to protect workers from an occupational injury, illness, and death. Safe workplaces are only possible when everyone on the team knows how to recognize a hazard and how to prevent, mitigate, or correct it.
Meeting OSHA's training requirements can be complicated and somewhat subjective. It's important for employers and L&D professionals to understand the factors they must consider when building a curriculum.
What Are OSHA's Training Requirements?
OSHA's official training compliance policy is that employers must train employees in everything they need to know to do their job safely. It's as simple and as complicated as that.
Workers only need training in standards that apply their duties and environment, while supervisors need training in all of the standards for everyone they oversee.
Leaving the requirements for training compliance so far open to interpretation is a feature, not a bug. It forces each employer to consider the true training needs of each employee. It also allows OSHA to judge training compliance based on specific circumstances and rule in favor of what's best for worker safety without being hamstrung by loopholes.
Despite the deliberate vagueness of what counts as comprehensive training compliance, there are more than 100 mandatory OSHA training courses required for employers and employees to stay compliant.
Finally, OSHA requires training to be available "in a manner" and "in language" that can be understood by the worker. This makes employers responsible for resolving concerns related to literacy, vocabulary, disability, and a lack of English fluency.
OSHA 10-Hour Construction
OSHA Outreach for construction covers 29 CFR 1926 regulations. DOL card included.
OSHA 30-Hour Construction
OSHA 30 Outreach for construction covers 29 CFR 1926 regulations. DOL card included.
OSHA 10-Hour General Industry
OSHA Outreach general industry covers 29 CFR 1910 regulations. DOL card included.
OSHA 30 Hour General Industry
OSHA 30 Outreach general industry covers 29 CFR 1910 regulations. DOL card included.
How Does OSHA's Required Training Vary by Industry?
OSHA's jurisdiction and standards vary by industry, so compliance training does as well.
Some industries are regulated by another agency entirely. This includes:
- Mariners, regulated by the US Coast Guard (USGS)
- Mining, regulated by the Mine Safety and Health Administration (MSHA)
- Aviation, regulated by the Federal Aviation Administration (FAA)
- Nuclear Facilities, regulated by the Department of Energy (DOE)
These industries still have to educate workers on their rights and protections under the Occupational Safety and Health Act (OSH Act), but specific safety measures and relevant training are created and enforced under their home agency.
Of the industries that fall under OSHA's jurisdiction, several have their own specific standards with training requirements. This includes:
- Construction (29 CFR 1926 and some of §1910)
- Shipyards (§1915, §1919, and some of §1910)
- Marine Terminals (§1917, §1919, and some of §1910)
- Longshoring (§1918, §1919, and some of §1910)
- Agriculture (§1928 and §1910)
All other industries fall under the "general" standards of §1910. That's a big umbrella, but not all "general" industries require the same level of training. More extensive training is needed for high-risk workers, including warehouse, manufacturing, and industrial employees.
Low-risk industries like office work may only call for topics like workers' rights, emergency action plans, and fire prevention.
Should Employers Provide Health and Safety Training on Any Other Topics?
"Everything they need to know" is a heck of an umbrella, so yes, you may need to add topics OSHA doesn't mandate.
There are a few sources of authority that might require extra training.
Firstly, some OSHA standards adopt other standards by reference (like those of the NFPA). Those adopted standards may contain additional training requirements not listed in OSHA's "mandatory training" publication.
Secondly, some states have their own Occupational Safety and Health agencies, which operate under the supervision of OSHA. Some of these agencies have standards that don't exist on the federal level, and some have similar standards that are simply more stringent.
State OSH standards may come with explicit training requirements, but even if they don't, you should train on relevant state specifics so workers know how to comply.
California, Michigan, Oregon, and Washington have rules that may call for special training, among others. Check your own state, county, and municipal regulations for local requirements.
Finally, the OSH Act contains a General Duty Clause that holds employers accountable for protecting workers from any recognizable hazard. This covers any safety or health threat that isn't specified by existing OSHA standards.
As an example, Workplace Violence training doesn't appear anywhere in OSHA's standards, but it helps mitigate a recognizable threat.
Keep in mind that training can't be the only mitigation method. OSHA requires employers to put engineering and administrative controls in place before resorting to other measures. However, employee training can be a helpful part of fulfilling the General Duty obligation.
How Frequently is OSHA Compliance Training Required?
Standards that require training usually have a minimum frequency attached. The most common recommendation is "at least yearly."
However, there are some circumstances where compliance training is required sooner. Workers should receive follow-up or refresher training if:
- New workplace hazards arise
- Standards, policies, or procedures change in a way that impacts safety training
- Individual performance implies that training was inadequate or misunderstood
Any safety training on non-prescribed topics should be repeated as often as necessary to ensure workers can recognize and address the relevant health and safety threats.
How is Training Compliance Determined by OSHA?
Employers are required to keep records of OSHA compliance training for all employees, and during an inspection, OSHA compliance officers will check your paperwork to make sure everyone's up to date.
However, they'll also quiz workers to check how well they understand the safety rules and hazards of their jobs. They'll look for safety violations that lead them to conclude that training is inadequate.
In other words, your workers can't just do the training. To pass muster, the training must actually work.
Does OSHA 10/30 Training Satisfy OSHA Training Requirements?
OSHA goes out of its way to disclaim that its Outreach Training, which comes in both 10-hour and 30-hour versions, does NOT fulfill its mandatory training requirements.
In a practical sense, this is not quite true.
OSHA Outreach courses aren't guaranteed to fulfill all of an employer's safety training obligations. It can, however, provide a solid foundation on common OSHA compliance training topics.
Employers who use Outreach Training should pick a curriculum that best suits their workers, then make educated decisions on which employees require further safety training and in what areas.
How Do You Choose the Right OSHA Outreach Course?
First, you need to choose the right industry. There are separate Outreach programs for General Industry, Construction, Shipyards, Marine Terminals, and Longshoring.
Agriculture doesn't have its own Outreach Training. Instead, OSHA provides a list of recommended resources, and a few training providers have devised Agriculture-focused versions of General Industry Outreach curriculum.
Within each "industry," Outreach Training is divided by level into 10-hour and 30-hour. The 10-hour version is suitable for entry-level workers (and anyone else who doesn't have supervisory responsibilities). It's intended to cover workers' rights and protections, as well as the most broadly applicable safety topics for that industry.
The 30-hour Outreach course is designed for supervisors and managers, including forepeople, engineers, site leads, project managers, and safety specialists. Some of those additional hours go towards managerial OSH responsibilities, but most go towards additional safety topics.
To ensure the welfare of entire teams, supervisors need a broader and deeper understanding of safety issues, including hazards that only impact specialized labor.
What Does OSHA Outreach Training?
OSHA designs Outreach Program curriculum guidelines for a balance of consistency and flexibility. They prescribe a certain number of mandatory, elective, and optional topics. That allows individual trainers to tailor the curriculum to be relevant to specific sets of workers.
Due to the nature of the General Industry catchall, its Outreach Training is the biggest wild card in terms of choosing the right curriculum. Most General Industry programs are geared towards manufacturing, warehousing, and industrial workers. Those industries have the highest risk workers in the category, so they make up the bulk of demand.
However, you can also find OSHA-authorized trainers who tailor the curriculum for other industries like healthcare, the culinary arts, or even entertainment.
When is OSHA 10/30 Training Required?
OSHA considers its Outreach Training entirely voluntary. However, certain jurisdictions and employers find the consistency of Outreach curriculum useful as a minimum benchmark for occupational safety training.
That's why certain job listings will include a "Department of Labor (or DOL) card" requirement for high-risk industries. A DOL card is a plastic wallet card you get after successfully completing an Outreach course. It's sometimes also referred to as "OSHA certification" or "becoming OSHA certified," even though OSHA discourages the use of these terms.
States and cities often use DOL cards as a concrete sign that contractors bidding for public funds will take construction safety seriously. These jurisdictions will require a DOL card of every construction worker on a public works project, sometimes only above a minimum contract value. Connecticut, Massachusetts, Missouri, New Hampshire, New York State, Rhode Island, and West Virginia have such public works requirements. So does Miami-Dade County in Florida.
A valid DOL card is required for all construction workers in the state of Nevada and the city of Philadelphia. New York City is currently phasing in construction safety training requirements that are stricter than any in the country. These requirements – called Site Safety Training (SST) – will go well beyond a DOL card and will apply to any job larger than a 3-family home.
Finally, Nevada is home to the only statutory requirement in the country for a DOL card in General Industry. All paid workers in the entertainment industry need one.
In most jurisdictions that require a DOL card, there is a prescribed renewal frequency. Individual employers who require a DOL card may have their own preferences.
Where Do You Get OSHA 10-Hour or 30-Hour Training?
When someone finishes a trainer course through the OSHA Training Institute (OTI), they earn the authorization to issue official 10-hour and 30-hour DOL cards to workers in a single industry. You can find authorized third parties that offer training online, in person, or as a blended approach.
To be eligible to earn a trainer card, you need a certain amount of occupational safety and health experience within that industry. An OSHA-authorized trainer's credentials have to be renewed every 4 years.
It's important to verify a trainer's credentials through OSHA.gov when choosing a provider. In addition to a list of currently authorized trainers, OSHA has a watchlist for trainers whose authorization has been revoked or suspended.