OSHA Training Required Year After Year . . .
The new year is in full swing now, so it’s time to start planning your OSHA training schedule for the next 12 months. To help make sure you don’t miss anything, I thought it might be helpful to go through all the federal OSHA standards for construction and general industry and compile a list of the ones I found that specifically require employers to provide their workers with mandatory refresher training and information annually.
So, here is my list of Federal OSHA standards that specifically mandate annual OSHA refresher training and information:
| Federal OSHA Standard | Annual Refresher Training Requirement |
| Occupational Noise Exposure – 1910.95(k)(2) | The training program shall be repeated annually for each employee included in the hearing conservation program. Information provided in the training program shall be updated to be consistent with changes in protective equipment and work processes. |
| Hazardous Waste Operations and Emergency Response – 1910.120(e)(8) – 1910.120(p)(7)(i) – 1910.120(q)(8)(i) | Refresher training. Employees specified in paragraph (e)(1) of this section, and managers and supervisors specified in paragraph (e)(4) of this section, shall receive eight hours of refresher training annually on the items specified in paragraph (e)(2) and/or (e)(4) of this section, any critique of incidents that have occurred in the past year that can serve as training examples of related work, and other relevant topics. New employees. The employer shall develop and implement a training program which is part of the employer’s safety and health program, for employees exposed to health hazards or hazardous substances at TSD operations to enable the employees to perform their assigned duties and functions in a safe and healthful manner so as not to endanger themselves or other employees. The initial training shall be for 24 hours and refresher training shall be for eight hours annually. Employees who have received the initial training required by this paragraph shall be given a written certificate attesting that they have successfully completed the necessary training. Refresher training. Those employees who are trained in accordance with paragraph (q)(6) of this section shall receive annual refresher training of sufficient content and duration to maintain their competencies, or shall demonstrate competency in those areas at least yearly. |
| Respiratory Protection – 1910.134(k)(5) | Retraining shall be administered annually, and when the following situations occur: (i) Changes in the workplace or the type of respirator render previous training obsolete; (ii) Inadequacies in the employee’s knowledge or use of the respirator indicate that the employee has not retained the requisite understanding or skill; or (iii) Any other situation arises in which retraining appears necessary to ensure safe respirator use. |
| Fire Brigades – 1910.156(c)(2) | The employer shall assure that training and education is conducted frequently enough to assure that each member of the fire brigade is able to perform the member’s assigned duties and functions satisfactorily and in a safe manner so as not to endanger fire brigade members or other employees. All fire brigade members shall be provided with training at least annually. In addition, fire brigade members who are expected to perform interior structural fire-fighting shall be provided with an education session or training at least quarterly. |
| Portable Fire Extinguishers – 1910.157(g)(2) – 1910.157(g)(4) | The employer shall provide the education required in paragraph (g)(1) of this section upon initial employment and at least annually thereafter. The employer shall provide the training required in paragraph (g)(3) of this section upon initial assignment to the designated group of employees and at least annually thereafter. |
| Fixed Extinguishing Systems – 1910.158(b)(10) | The employer shall train employees designated to inspect, maintain, operate, or repair fixed extinguishing systems and annually review their training to keep them up-to-date in the functions they are to perform. |
| Mechanical Power Presses – 1910.217(h)(13)(i) | The operator training required by paragraph (f)(2) of this section shall be provided to the employee before the employee initially operates the press and as needed to maintain competence, but not less than annually thereafter. It shall include instruction relative to the following items for presses used in the PSDI mode. |
| Asbestos – 1910.1001(j)(2)(i) & (ii) – 1910.1001(j)(2)(iv) | (i) The employer shall train each employee who is exposed to airborne concentrations of asbestos at or above the PEL and/or excursion limit in accordance with the requirements of this section. The employer shall institute a training program and ensure employee participation in the program. (ii) Training shall be provided prior to or at the time of initial assignment and at least annually thereafter. (iv) The employer shall also provide, at no cost to employees who perform housekeeping operations in an area which contains ACM or PACM, an asbestos awareness training course, which shall at a minimum contain the following elements: health effects of asbestos, locations of ACM and PACM in the building/facility, recognition of ACM and PACM damage and deterioration, requirements in this standard relating to housekeeping, and proper response to fiber release episodes, to all employees who perform housekeeping work in areas where ACM and/or PACM is present. Each such employee shall be so trained at least once a year. |
| Thirteen Carcinogens – 1910.1003 – 1016(e)(5)(I) | A review of this section at the employee’s first training and indoctrination program and annually thereafter. |
| Vinyl Chloride – 1910.1017(j)(1)(ix) | A review of this standard at the employee’s first training and indoctrination program, and annually thereafter. |
| Inorganic Arsenic – 1910.1018(O)(1)(ii) | (ii) The training program shall be provided by October 1, 1978, for employees covered by this provision, at the time of initial assignment for those subsequently covered by this provision, and at least annually for other covered employees thereafter; and the employer shall assure that each employee is informed of the following: |
| Access to Employee Exposure and Medical Records – 1910.1020(g)(1)(i) – (iii) | Upon an employee’s first entering into employment, and at least annually thereafter, each employer shall inform current employees covered by this section of the following: (i) The existence, location, and availability of any records covered by this section; (ii) The person responsible for maintaining and providing access to records; and (iii) Each employee’s rights of access to these records. |
| Lead – 1910.1025(l)(1)(iv) | The training program shall be repeated at least annually for each employee. |
| Cadmium – 1910.1027(m)(4)(ii) | Training shall be provided prior to or at the time of initial assignment to a job involving potential exposure to cadmium and at least annually thereafter. |
| Benzene – 1910.1028(j)(3)(i) | The employer shall provide employees with information and training at the time of their initial assignment to a work area where benzene is present. If exposures are above the action level, employees shall be provided with information and training at least annually thereafter. |
| Coke Oven Emissions – 1910.1029(k)(1)(iii) | The training program shall be provided at least annually for all employees who are employed in the regulated area, except that training regarding the occupational safety and health hazards associated with exposure to coke oven emissions and the purpose, proper use, and limitations of respiratory protective devices shall be provided at least quarterly until January 20, 1978. |
| Bloodborne Pathogens – 1910.1030(g)(2)(ii) | (ii) Training shall be provided as follows: (A) – At the time of initial assignment to tasks where occupational exposure may take place; (B) – At least annually thereafter. |
| Cotton Dust – 1910.1043(i)(1)(ii) | The training program shall be provided prior to initial assignment and shall be repeated annually for each employee exposed to cotton dust, when job assignments or work processes change and when employee performance indicates a need for retraining. |
| Acrylonitrile (Vinyl Cyanide) – 1910.1045(O)(1)(ii) | Training shall be provided at the time of initial assignment, or upon institution of the training program, and at least annually thereafter, and the employer shall assure that each employee is informed of the following: (A) – The information contained in appendixes A and B; (B) – The quantity, location, manner of use, release, or storage of AN, and the specific nature of operations which could result in exposure to AN, as well as any necessary protective steps; (C) – The purpose, proper use, and limitations of respirators and protective clothing; (D) – The purpose and a description of the medical surveillance program required by paragraph (n) of this section; (E) – The emergency procedures developed, as required by paragraph (i) of this section; (F) – Engineering and work practice controls, their function, and the employee’s relationship to these controls; and (G) – A review of this standard. |
| Ethylene Oxide – 1910.1047(j)(3)(i) | The employer shall provide employees who are potentially exposed to EtO at or above the action level or above the excursion limit with information and training on EtO at the time of initial assignment and at least annually thereafter. |
| Formaldehyde – 1910.1048(n)(2) | Frequency. Employers shall provide such information and training to employees at the time of initial assignment, and whenever a new exposure to formaldehyde is introduced into the work area. The training shall be repeated at least annually. |
| Methylenedianiline – 1910.1053(k)(3)(i) | The employer shall provide employees with information and training on MDA, in accordance with 29 CFR 1910.1200(h), at the time of initial assignment and at least annually thereafter. |
| 1,3-Butadiene – 1910.1051(l)(2)(iii) | Training shall be provided prior to or at the time of initial assignment to a job potentially involving exposure to BD at or above the action level or STEL and at least annually thereafter. |
Important caveats to keep in mind: First of all, this list shows only 1910 general industry standards. But there are several 1926 construction standards for some of the same topics that simply state that the employer must comply with rules contained in the corresponding general industry standard (examples include 1926 construction rules for asbestos and hazwoper).
Also be aware that this list only addresses those Federal OSHA standards that directly require the employer to provide affected workers with training or information at least once a year. It does not include those standards that may require refresher training in special events, such as when confined space procedures or equipment are changed, or when an annually required program/procedure review shows a deficiency (e.g.: lockout/tagout, electric power generation, transmission and distribution, forklift operator evaluation . . .).
Nor does our list of training requirements address those OSHA standards that incorporate by reference specific training sponsored by organizations other than OSHA (like the Red Cross or American Heart Association) that might require annual refresher training (e.g.: some first aid or CPR classes mentioned in the OSHA standards for medical care). This list also does not mention annual training requirements included in consensus standards that OSHA may enforce through the application of the general dusty clause of the OSHA Act, such as the API standard that requires Hydrogen Sulfide / H2S annual refresher training. In addition, this list does not include any redundant OSHA training requirements already listed in other OSHA standards requiring annual refresher training (e.g.: the overhead crane standard requires employees using portable fire extinguishers be trained, but do not mention the annual refresher training for fire extinguishers which is specifically required in 1910.157).
This list also does not include the annual “practice” drill using simulated rescue operations required for employees who perform permit-required confined space rescues.
Last but not least; Keep in mind that these references apply to federal OSHA regulations; there are a few (but not many) State Plan OSHA Program standards that may require annual refresher training on a topic that Federal OSHA does not (e.g.: annual refresher training for hazard communication is required by the State Plan OSHA program in Minnesota (aka MN-OSHA).
Were you surprised by any of the requirements appearing on this list? Was there a specific federal OSHA standard that you though required annual refresher training but actually does not? If so, or if you know of another federal OSHA standard not appearing on the list that specifically requires annual training, please scroll down to share your comments with us in the “Comments” section of this post. And last but not least, I encourage you to Share This Blog Post with Others in Your Network who might benefit from reading this information. Thanks – Curtis
