In the past 4-5 months, I have received numerous phone calls and e-mails from friends/clients regarding their desire to hold an OSHA 10-hour course for their employees. Most of this is driven by the idea that they believed, as they were told by some less than scrupulous consultants, that OSHA would accept their 10-hr card as meeting the required annual safety training for employees. One such company, not a client – but referred to me by a client, was cited for not having conducted safety training on the required topics and the topics that were covered in the 10-hr course(s) were not adequate for the at-risk employees. As you can imagine, they were pretty ticked off as they had been having their employees attend a 10-hr course each year for the past three years (doing many of those courses online during the pandemic) only to find out that these 10-hr courses did not replace their former annual safety training courses. This company admitted that they used to spend 30-50 hours per employee on safety topics annually and somehow thought they could do it all in 10 hours and show OSHA a “card” (what we have come to call the “get-out-of-jail-free” card) during an OSHA inspection.
We do NOT provide OSHA outreach training courses – we believe they are woefully inadequate and often taught by less-than-qualified personnel who attended a 1-week training course themselves to become “certified” instructors. These courses may VERY MINIMALLY help an employer meet the required safety and health training they are responsible for providing to their employees. Even OSHA will agree the intent of the 10-hr is NOT to meet minimum compliance obligations or address specific workplace hazards. SO BUYER BEWARE when some consultant tries to sell you a 10-hr OSHA course and claims it is “all you need to meet OSHA compliance”!
Here is the REQUIRED content for an OSHA 10-hr, as well as the time frame to be spent on the required content:
1. Mandatory – Six (6) hours
a) Introduction to OSHA – One (1) hour
Covers workers’ rights, employer responsibilities and how to file a complaint. It includes helpful worker safety and health resources. It also provides samples of a weekly fatality and catastrophe report, safety data sheet and the OSHA Log of Work-Related Injuries and Illnesses (OSHA form 300).
b) Walking and Working Surfaces, including fall protection – One (1) hour
c) Exit Routes, Emergency Action Plans, Fire Prevention Plans, and Fire Protection – One (1) hour
d) Electrical – One (1) hour
e) Personal Protective Equipment – One (1) hour
f) Hazard Communication – One (1) hour
2. Elective – 2 hours
Must present at least two (2) hours of training on the following topics. At least two topics must be presented. The minimum length of any topic is one-half (1/2) hour
a) Hazardous Materials
b) Materials Handling
c) Machine Guarding
d) Introduction to Industrial Hygiene
e) Bloodborne Pathogens
f) Ergonomics
g) Safety and Health Program
h) Fall Protection
3. Optional – Two (2) hours
Teach other general industry hazards or policies and/or expand on the mandatory or elective topics. The minimum length of any topic is one-half (1/2) hour.
These are not a bad assortment of topics to cover in a course designed such as the 10-hr; however, a lot of employees are not in jobs or doing tasks where these topics are applicable to their work, and the hazards AND many workplaces will have employees doing work/tasks in which they need safety training and the content is NOT on the agenda for a 10-hr.
So feel free to have select personnel attend the OSHA 10 and 30-hour courses, BUT do so as “additional education” for them – NOT intending for the training to be a one-and-done course to “check the box” for the required safety training employees need.