Centurion Insurance Services is pleased to provide our clients with value added information on loss control from our in-house advisor, Rob Brooks. This post is part one of a series on OSHA training requirements, which continues in two further installments. Part Two – Part Three
COMPLETE YOUR REQUIRED OSHA TRAINING!
Failing to provide employees with OSHA required training can be a very costly proposition in the event of an OSHA inspection. Although all workplaces should strive to maintain a safe environment, accidents do occur. In some instances, these result in a workplace fatality or serious injury event. With that, one of the first questions that an OSHA accident investigator will probably ask management is, “Produce records showing the injured or deceased worker was adequately trained to safely perform the task they were doing at the time of the accident.”
It is not uncommon for OSHA to issue penalties for failure to train employees in the five and six figure financial range. The OSHA penalty schedule as of June 2019 is up to a maximum of $13,260 for a Serious Violation. It is a whopping $132,598 maximum for a Willful or Repeat Violation. OSHA loosely defines a Willful Violation as one where the employer knew or should have known of a specific statutory requirement on their part and still failed to take the proper steps to protect their workers.
Also, as part of the violation remediation process, OSHA will usually impose a deadline for completion of training. Employers who fail to fully comply with the deadline can be subject to additional penalties of up to $13,260 per day.
Do you know?
Do you know?
How many mandatory subjects require training for all employees?
OSHA has seven subjects on which all employees must be initially trained. This training not only encompasses all new employees, but any other employees who have not received the training. Centurion advises employers not to rely on an individual worker’s memory of mandatory training they received over their course of employment. When in doubt, management should always err on the side of caution and include these workers in their classes.
A BRIEF OVERVIEW OF OSHA’S SEVEN REQUIRED TRAINING SUBJECTS FOR ALL EMPLOYEES:
Access to Employee Medical & Exposure Records: An employer must inform employees of the type, location & availability of their work-related medical and exposure records. They must also inform them of their right to access this information. An example of a medical record would be copy of a pre-employment physical. An exposure record could be an indoor air quality sampling report conducted by an environmental vendor.
Accident Reporting & Record Keeping: Organizations are required to instruct their employees on the definition of an OSHA recordable or reportable incident, how they are to report such incidents to management and the means of recordkeeping. An OSHA recordable incident (on the OSHA 300 Log) is defined as any injury or illness event that requires medical treatment beyond first aid. An OSHA reportable incident includes accidents that resulted in employee death, hospitalization, the loss of a limb, or the loss of an eye. These events must also be reported directly to OSHA within a specific time limit.
Emergency Action Plan: The employer must present each worker with an overview of the emergency alarm systems and communication methods for emergencies in their workplace. These emergencies could include: fire, chemical spills, medical situations, severe weather, electricity failure and workplace violence incidents.
Fire Prevention Plan: All employees are to be informed of the fire hazards associated with their job and the procedures needed to prevent or minimize the chances of fire.
Hazard Communication: This training is to explain and reinforce the information presented to employees on potentially hazardous chemicals in the workplace though written mediums such as product labels and safety data sheets. The employee must also be instructed how to apply this information to their workplace activities. Common over-the-counter chemicals or products, such as those used for routine housekeeping, do not usually have to be included in this training.
Portable Fire Extinguishers: If the employer requires workers to help in the fighting of small workplace fires, they must be provided training. This includes the kinds of anticipated fires in the workplace, the various types of fire extinguishers and how to effectively utilize those extinguishers to control a fire. Extinguisher training also has to be conducted annually.
Safety Signs, Labels & Symbols: This training is to inform all employees of the purpose of having safety related signage in the workplace and their various meanings.