Training is an essential component of many of the standards set by OSHA that are most frequently violated year after year. There are important training requirements for fall protection, respiratory protection, hazard communication, powered industrial trucks, lockout-tagout, machine guarding, and electrical safety – all standards in the top ten most frequently cited rules for fiscal year 2014.
Employers get tripped up by training requirements for different reasons. Sometimes individuals trained for specific supervisory/program oversight “designated” roles are not selected and properly trained. Knowing which employees require training due to exposures to different hazards can be problematic. Refresher training can be overlooked. OSHA inspectors often discover an absence of required training when interviewing employees, reviewing paperwork documentation, and investigating fatalities and serious injuries.
The scope and complexity of OSHA standards may make it difficult to find all the references to training. To help, OSHA has excerpted its training-related requirements in a booklet titled, “Training Requirements in OSHA Standards and Training Guidelines” (www.osha.gov/Publications/2254.html).
To illustrate the diverse nature of OSHA’s training requirements, here are some recent training-related citations.
• Ohio-based manufacturer Vista Window Company LLC was cited for failing to protect workers from operating parts of machinery by the use of guards and failing to develop procedures for applying locking devices to prevent unintentional operation of machinery during service and maintenance. Other violations included a lack of training on workplace hazards and procedures. In total, OSHA issued 16 serious and three other-than-serious violations and proposed penalties totaling $79,200.
• Marietta Corp., a hotel soap and shampoo manufacturer from Syracuse, N.Y., was fined nearly $104K for exposing employees to dangerous chemical and fire hazards and blocking emergency exit routes. Inspectors found training-related violations that included a failure to train and medically check workers who were wearing respirators; failure to train employees in the use of dangerous chemicals; and forklift operators who did not receive refresher training.
• OSHA cited Mid-America Steel Products, Inc., a trailer parts manufacturer, for 19 violations – 17 serious – and proposed penalties of $41,200. The serious violations include failing to maintain a hearing conservation program for workers exposed to noise levels greater than 85 decibels, failing to provide required training, and not guarding machinery.
• OSHA issued 14 citations, including eight repeated violations, to DuPont Yard Inc. after an investigation of its Homerville, Ga., facility. The company was fined nearly $180,000. Training-related violations included not providing workers with forklift training, as well as not training employees to operate fire extinguishers.
• Following a worker fatality, Ocean Springs, Miss., contractor Thomas Matthews Framing LLC was cited for one willful and two serious violations, with proposed placement in the agency’s Severe Violator Enforcement Program. Gerald Moran suffered fatal injuries after losing his balance and falling more than 20 feet. Serious violations included not training workers to recognize and prevent fall hazards. Proposed penalties totaled $58,700.
• OSHA charged Duke Energy Florida Inc. with one willful and five serious safety violations, and issued fines totaling $90,000, following an investigation of a worker’s death. Christopher Lee Dasher was testing and repairing electrical transformers at a substation in Reddick when he was electrocuted by more than 10,000 volts. One of the serious citations issued was for failure to provide training to workers who assisted with transformer testing.