In the PSM/RMP world, the battle rages on with regards to “verification of knowledge” for those receiving training related to their work in, on and adjacent to a PSM/RMP covered process. Yet for those safety professionals not working at a PSM/RMP facility, you too have a standard, that will just about cover ALL workplaces, that REQUIRES the employer to ensure workers understood the training. That standard is 1910.132(f)(2)…
Each affected employee shall 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.
Here is what the PPE OSHA CPL states about PPE and the employee(s) knowledge…
The CSHO shall determine whether each employee performs work requiring the use of PPE can demonstrate an understanding of the required training, and the ability to use PPE properly. Lack of an employee’s knowledge in or use of, assigned PPE would be indicative that the employee has not retained the requisite understanding or skill. Cite 29 CFR 1910.132(f)(2) where the employer fails to meet this requirement.
…
The CSHO shall determine whether the employee knows when and what eye, face, head, foot and hand PPE is necessary, how to properly don, doff, adjust and wear the assigned PPE, the limitations on the assigned PPE, and the proper care, maintenance, useful life and disposal of the assigned PPE. If each employee required to use the assigned PPE does not know all of the above, a citation shall be issued under 29 CFR 1910.132(f)(3)(iii) for the failure to retrain.
So OSHA is NOT requiring any additional documentation such as a written test, but they do expect that employees be able to DEMONSTRATE when and what eye, face, head, foot and hand PPE is necessary, how to properly don, doff, adjust and wear the assigned PPE, the limitations on the assigned PPE, and the proper care, maintenance, useful life and disposal of the assigned PPE.
CLICK HERE for the PPE CPL