"IF IT ISN'T DOCUMENTED, IT DIDN'T HAPPEN"
We’ve all heard the old safety training saying, “if it isn’t documented, it didn’t happen.” This isn’t always necessarily true, but the statement does emphasize the need for effective training documentation. Effective documentation provides evidence of the employer’s good faith efforts toward complying with training requirements defined by the Occupational Safety and Health Administration (OSHA) as well as other regulatory agencies.
While many OSHA standards require training, many do not require training documentation. Several general industry standards such as Process Safety Management, Personal Protective Equipment, Respiratory Protection, Permit Required Confined Space, Lockout Tagout, and Powered Industrial Trucks require training documentation. However, many standards reference training, but do not have specific language regarding documentation. Should an OSHA compliance officer inspect an employer’s facility, they will most likely look for evidence that safety training is provided for standards requiring training documentation and possibly those that do not. The most effective strategy is to document each safety training session regardless of the requirements.
Employers rely on various forms of training to comply with OSHA standards including classroom, online, hands-on, or skills-based training or any combination of these methods. At a minimum, classroom training documentation should include a description of the subject matter, the date, the names of the attendees, and the name of the instructor. In addition, consider requiring a signature alongside the printed name of the attendee and instructor, and a description of any materials used to include references to videos, online content, handouts, presentations, hands-on exercises, and conversations specific to company requirements.
Several years ago, I attended a workplace safety symposium. An administrative law judge discussed several cases he presided over and provided the group with some recommendations for complying with OSHA training requirements. He indicated that over his lengthy career many cases were decided based on employee training effectiveness. He indicated that on many occasions employees were shown videos, sometimes over the lunch hour, where a sign-in sheet was used to document the training. He expressed concern over the delivery, timing, and employee comprehension. He also referenced the value of testing, not only as an additional form of documentation, but also proof of comprehension and understanding of the topic. He explained that both written and online testing provided within a learning management system are effective ways to demonstrate comprehension of the subject matter.
Joe Mlynek is a partner and subject matter expert at Safety Made Simple, Inc. He has over 20 years of experience in safety at the corporate level and as a consultant. He is a Certified Safety Professional (CSP) and Occupational Safety and Health Technician (OHST). Joe can be reached at firstname.lastname@example.org