It’s not too late to conduct your annual refresher safety training! With all the COVID 19-related changes that everyone has had to make in the workplace this year, it’s easy to see how this requirement could slip through the cracks.
In light of the pandemic, OSHA is making some allowances for lapses in annual training requirements such as for companies that were required to close for a period of time.
That said, OSHA is requiring that companies demonstrate that they have made a good faith effort to comply with annual training requirements including the use of virtual training options and other means of remote communication. The use of virtual training has been a great option for many companies and has even proven to make annual refresher training easier to schedule!
Which OSHA standards specifically require refresher training?
- The OSHA Bloodborne Pathogens Standard (29 CFR 1910.1030) requires that annual training be provided within one year (i.e., 12 months) of the previous training. The annual training must include all of the training topics that are required for the initial training.
- The OSHA Lab Standard (29 CFR 1910.1450) requires retraining when new hazards are introduced that create new exposure situations, but the frequency of refresher training can be determined by the employer. Annual refresher training is always considered best practice!
- The OSHA Standard on Emergency Action Plans (29 CFR 1910.38) requires retraining when employees’ responsibilities under the plan change (e.g., a change in the Emergency Coordinators), or when the Plan changes (e.g. when the evacuation route or rally point change). Once again, annual refresher training is considered best practice, even if there are no changes!
- The OSHA Standard on Portable Fire Extinguishers (29 CFR 1910.157) requires annual refresher training to familiarize employees with the general principles of fire extinguisher use whenever they are provided for employee use in the workplace. This is an often-overlooked annual training requirement!
- The OSHA Respiratory Protection Standard (29 CFR 1910.134) requires annual refresher training at all workplaces that have mandatory respiratory protection programs, including programs for N95 use. Retraining may be required sooner if the type of respirator required changes, or inadequacies in employees’ knowledge or use of the respirator indicate that the employee has not retained the required understanding or skill, or any other situation arises in which retraining appears necessary to ensure safe respirator use.
This isn’t an exhaustive list of OSHA standards that have specific annual/refresher training requirements. Training required by other OSHA standards is summarized in their guidance document Training Requirements in OSHA Standards.
For more information on OSHA training requirements, or for assistance with meeting your company’s 2020 training needs, please email firstname.lastname@example.org.
This blog was written by Beth Graham, our Associate Director of Quality, Research, and Training who has been with Safety Partners Inc. for the last 11 years.