Are there annual mandatory safety training topics that must be conducted in order to be compliant with OSHA?
Certainly, the outcome varies based on the nature of the job assignments, the particular risks that employees may come across during their daily work routines, and, most importantly, the specific regulatory frameworks associated with these tasks and risks within the respective work sector. Consequently, the simple response is that each organization is distinct, and there's no one-size-fits-all answer to this question.
Let's shed some more light on this matter...
When considering federal OSHA guidelines, it's advisable to consult the following resource: OSHA 2254 Training Requirements in OSHA Standards. This document serves as an excellent reference for OSHA's training mandates.
Pro Tip: To expedite your search, use the "CTRL-F" function to locate instances of the term "annual" within the document. This will enable you to pinpoint all the specific standards that pertain to annual refresher training. As you navigate through each section and assess the standards related to yearly training prerequisites, make sure to match these requirements with the tasks and hazards relevant to your workforce. Subsequently, integrate the mandatory training into your annual safety training program.
Below are a few examples from this document that apply to Construction:
1926.62 Lead in Construction (l) Communication of hazards (iv) The employer shall also provide the training program at least annually for each employee who is subject to lead exposure at or above the action level on any day.
1910.134 Respiratory protection (k) Training and information. This paragraph requires the employer to provide effective training to employees who are required to use respirators. The training must be comprehensive, understandable, and recur annually, and more often if necessary.
The instances mentioned above pertain primarily to construction tasks. However, it's worth noting that many contractors sometimes overlook the fact that their activities may also fall under General Industry regulations, contingent upon the specific tasks they're engaged in. There might be scenarios in which they're carrying out warranty or service-related work, making them subject to OSHA guidelines such as lockout/tagout regulations outlined in 29 CFR 1910.147 or other standards that impose an annual training obligation.
Other General Industry Standards that require annual training include:
1910.95 Occupational Noise Exposure (k)(2) The training program shall be repeated annually for each employee included in the hearing conservation program.
1910.120 Hazardous Waste Operations (p)(7)(ii) Current employees shall receive eight hours of refresher training annually.
1010.157 Portable Fire Extinguishers (g)(1) Where the employer has provided portable fire extinguishers for employee use in the workplace, the employer shall also provide an educational program to familiarize employees with the general principles of fire extinguisher use and the hazards involved with incipient stage firefighting. (2) The employer shall provide the education required in paragraph (g)(1) of this section upon initial employment and at least annually thereafter.
Another specific standard that should be considered, although it doesn’t state “annual” is listed below because it is often cited by OSHA compliance officers whenever there isn’t a specific training requirement.
1926.21(b)(2) The employer shall instruct each employee in the recognition and avoidance of unsafe conditions and the regulations applicable to his work environment to control or eliminate any hazards or other exposure to illness or injury.
Lastly, even if there isn’t a specific statement in the OSHA regulation that say the employer must provide annual training (or retraining) it is typically seen as an industry best practice to do annual refresher training on many, if not all safety training.
Continuous safety training will yield recurring benefits, as it leads to reduced employee injuries and illnesses, improved morale, and ultimately results in decreased insurance premiums for the company.
Yellowknife Safety provides live, online Hazard Recognition Training for any type of business or industry. Please contact us at tdussault@yellowknifesafety.com for more information or to set up a training!
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