There was some legal advice given today on a social media site regarding documenting our safety training with sign-in sheets, so if OSHA ever asked for records to show an employee was “trained”, the employer would be able to show the sign-in sheet. The advice even contained the statement:
Your safety training in this respect does not need to be long – in theory, it could even be less than one minute. All of this training is worthy of being documented, even if it can be given in one minute or less – and, despite the brevity, it can still save a life. And, (since I’m a lawyer – can’t forget that) it can protect you legally as well.
These comments just blew me away but in his/her defense they were speaking as a lawyer and not a safety professional. But these comments represent the struggles of modern-day safety… too many businesses work to satisfy the minimum standards of a government agency rather than working towards what is best for their workers.
This leads me to one of our top findings over 20 years of auditing… 1910.132(f)(2)
When OSHA overhauled its PPE standards and began requiring Certified PPE Hazard Assessments, it also required that PPE training be VERIFIED by having EACH…
employee demonstrate an understanding of the training specified in paragraph (f)(1) of this section, and the ability to use PPE properly, before being allowed to perform work requiring the use of PPE.
Paragraph (f)(1) was expanded to include specific training expectations.
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1910.132(f) Training. 1910.132(f)(1) The employer shall provide training to each employee who is required by this section to use PPE. Each such employee shall be trained to know at least the following: 1910.132(f)(1)(i) When PPE is necessary; 1910.132(f)(1)(ii) What PPE is necessary; 1910.132(f)(1)(iii) How to properly don, doff, adjust, and wear PPE; 1910.132(f)(1)(iv) The limitations of the PPE; and, 1910.132(f)(1)(v) The proper care, maintenance, useful life and disposal of the PPE. |
Even at the simplest of workplaces that utilize safety glasses, hearing protection, and safety-toed footwear the training on just these three (3) pieces of PPE could take 30-45 minutes, which will include the attendees demonstrating their ability to don, doff, adjust, and inspect their PPE. Some employers will include a written test to verify the employee’s knowledge and understanding of the PPE’s limitations, useful life, maintenance, and disposal of PPE.
Now how can an employer meet these MINIMUM expectations using Computer Based Training (CBT)?
How can training on all the utilized PPE meet these expectations in a 15-minute training session?
Throw in Hi-Visibility clothing, Flame Retardant Clothing, Respirators, Personal Fall Arrest Systems, etc. and it can take hours and hours of training to meet even the OSHA minimum expectations as stated in .132(f)(1) and (f)(2).
When we are asked to provide a wide range of “PPE Training” to clients, we always require that each student in attendance be provided their own set of the PPE we will be training on. We actually do hands-on training when we get to .132(f)(1)(iii)-(v). We often do respiratory protection training separate from the basic PPE training, as it can take hours depending on the different levels of RP the facility may use. We also tend to hold PFAS training separately due to its complexity in understanding the limitations.
Here is some PPE that is pretty common in most workplaces, and all the above requirements are applicable to each type:
- Hardhat/Bump Cap
- Safety Glasses, Goggles, Face Shield, Welding Lens
- Respirators
- Hearing Protection (Muffs, Plugs, Caps have different training needs as they have different limitations and donning methods)
- Flame Retardent Clothing
- Chemical Suits (their permeation rates and compatibility limitations), Welding Leathers/FR, Welding Shielding
- Gloves (Leather, Chemical, Cut Resistance, Anti-Vibration/Fatigue, Voltage rated)
- Shoes (safety toed, meta-tarsal protection, static dissipation, EH rated)
And let’s not forget, 1910.132 also applies to protective shields and barriers that protect workers from a hazard. UV welding screens are a good example of these. So yes, training personnel on how to set them up, their limitations, their care, inspection, and storage is required. Another one that is often overlooked is sunscreen. As most can attest, many folks struggle with proper application, renewal, the UPF limitations, what sweat and water do to each application, etc. But workers who work outside and are exposed to UV will either need UV-rated clothing (comes with its own set of limitations) or sunscreen (i.e., a barrier).
So as you can see, there is a ton of work to do in order to just meet OSHA’s minimum expectations for EACH and EVERY piece of PPE, Protective Shields, and Barriers used in the workplace. In my days, we would spend around 8-10 hours per year just on PPE and that did NOT include the Emergency Response folks and their annual refreshers. We can have all the sign-in sheets we want to provide OSHA during an inspection, but that is NOT how we help workers perform their jobs safely.
Lastly, if this seems to be a lot, we have options… their called Engineering Controls and Administrative Controls.