Many of the OSHA standards explicitly require the employer to train employees in the safety and health aspects of their jobs. Other OSHA standards make it the employer's responsibility to limit certain job assignments to employees who are "certified," "competent," or "qualified" " meaning that they have had special previous training, in or out of the workplace. The term "designated" personnel means selected or assigned by the employer as qualified to perform specific duties. These requirements reflect OSHA's belief that training is an essential part of an effective safety and health program.
OSHA does not provide lesson plans or specific training elements, but rather, in performance oriented language, requires the employer to ensure that employees have the knowledge, skill and ability to safely perform their duties. OSHA sets the bar at a level that the employer must accede to and it is up to the employer to conduct the training that will accomplish the desired performance.
The use of performance oriented language is a direct result of the Agency's thinking about the workplace. No two workplaces are the same nor are the employees the same. Therefore, it is incumbent on the part of employers to develop and provide the specific training that will work in their workplaces. To assure that the desired performance is achieved, the employer must provide, "effective" training.
Effective training requires a change in behavior. The person responsible for the training must be able to recognize the performance that needs changing, provide a training unit that will ensure that behavior will change, and evaluate the employee to determine if the desired performance has been achieved. If performance has been permanently changed, then the training has been effective and it can be used for other employees. If performance has not been permanently changed, then the training unit needs to be reviewed with an eye toward how best to achieve the desired performance change.
To assist employers in this action, over 10 years ago, OSHA published a non-mandatory standard entitled Voluntary Training Guidelines. These guidelines have assisted employers who had little or no background in training. They were intended to provide a generic, non-exhaustive overview of the training requirements contained in OSHA standards. In this regard, they have been valuable as a means of reducing injuries and illnesses through better training. I would first like to provide an overview of the Voluntary Training Guidelines. Then I will discuss how employers can build on these general guidelines by using the more detailed guidance found in ANSI Z490.1, Criteria for Best Practices in Occupational Safety, Health, and Environmental Training, to develop and implement an effective safety and health training program. This will be done by providing an overview of the training requirements in OSHA's substance-specific standards and the training requirements in OSHA s new powered industrial truck operator training standard. During the discussion of the powered industrial truck training standard, I will relate how ANSI Z490.1 can be used to comply with the training requirements.