“SAFETY TRAINING DOCUMENTATION: When the weight of the paperwork equals the gross total weight of all your employees, your company MIGHT be OSHA compliant.”
Although the statement above was intended to be a little “tongue in cheek”, there is some truth to it. I can’t tell you how many times I have seen company owners attempt to explain how their safety training program should be in compliance with OSHA requirements.
Statements to the OSHA Compliance Officer like – “We hold daily tailgate meetings at each worksite” or “Our Supervisors train all the employees under their control how to do the job safely” tend to fall on deaf ears – unless you can prove the training was done with written documentation.
Remember that OSHA is visual. If they cannot see proof of training, it did not occur.
The Importance of Safety Training Documentation
Employee Safety Training Records are among the first things that the inspector wants to see when an OSHA compliance audit is performed at your company. Usually, the request for records occurs during the opening conference – when the inspector must tell you the reason for their visit. The opening conference is mandated by OSHA regulations and it must occur before an inspection of the facility begins.
Hopefully when the request for records comes, you can reach into your files and bring forth a folder bulging with meeting sign-in sheets, which include:
- Date of the meeting
- Topics discussed
- Names of all attendees printed and signed
A copy of the topic sheet discussed at the meeting should also be stapled to the attendance record. If your training record is substantial in size and if a cursory examination of attendance records and topic sheets indicates that real training pertinent to your operation has occurred, you win! OSHA Compliance Officers like to see thick training record folders!
No matter the type of business in which your company is engaged, there are OSHA standards (rules) that apply. Many of the OSHA standards that apply to your company have an employee training component – which requires all employees to receive training on the standard.
For example: OSHA requires all employers to have a written Emergency Action Plan designed to show employees the proper response to a workplace emergency – like fire, power outage, inclement weather, etc. Whether your business is an insurance office or a nuclear power plant, the Emergency Action Plan is required and documented training records show anyone interested that the training has been done.
Some OSHA Standards have requirements for annual refresher training or additional training to be done whenever a new piece of equipment or production process is introduced into the workplace. Again, documentation that the training has taken place in accordance with the standards will help keep the Compliance Officer happy – and lessen the likelihood of a citation and penalty.
Clients of Employers Resource are assigned a Regional Safety Manager as soon as the relationship with ERM is established. The Regional Safety Manager assists the new client in identifying applicable OSHA standards and required training components. Employers Resource supplies the needed written Employee Safety Programs and the training tools to ensure compliance with the OSHA Standards. Why not give us a call today to learn how Employers Resource Managers can help your business become compliant with OSHA-required employee safety training programs.