Occupational Safety And Heath Training Guidelines

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OccupationalSafety and HealthTraining GuidelinesFor Federal Agencies

Contents1.Background . 22.Introduction. 23.References. 34.Definitions . 35.Responsibilities . 46.7.5.1Agency Head . 45.2Designated Agency Safety and Health Official (DASHO) . 45.3Management Officials . 45.4Supervisory Employees. 55.5Employee Representatives . 55.6Certified Safety and Health Committee . 55.7Employees . 5Skills, Knowledge and Training Requirements . 56.1OSH Skills and Knowledge Base (Competencies) . 56.2Training Needs Assessment . 66.3Specific Training Requirements. 7Training Programs . 97.1Development . 97.2Delivery. 97.3Learning Methods . 107.4Assessment of Competency . 107.5Recording Competency . 117.6Duration of Competency . 118.Training Records . 119.Training Program Evaluation. 1110. OSHA Training Assessment . 12Appendix A:Training Needs Assessment (TNA) Sample . 13Page 1 of 15

1. BackgroundSection 19 of the Occupational Safety and Health Act of 1970 (the Act) includes provisionsto ensure safe and healthful working conditions for federal sector employees. Under thatsection, each federal agency is responsible for establishing and maintaining an effective andcomprehensive occupational safety and health (OSH) program consistent with standardspromulgated under Section 6 of the Act. On February 26, 1980, President Carter issuedExecutive Order (E.O.) 12196, Occupational Safety and Health Programs for FederalEmployees, which guides the heads of federal Executive Branch agencies in implementingSection 19 of the Act, and directs the Secretary of Labor (the Secretary) to issue a set of basicprogram elements to assist the various federal agencies in carrying out their responsibilities.These basic program elements are set forth at 29 CFR 1960 (Part 1960).The E.O. also specifies that the Federal Advisory Council on Occupational Safety and Health(FACOSH) shall advise the Secretary on matters relating to the occupational safety andhealth of the federal workforce. The Assistant Secretary for Occupational Safety and Healthchairs the Council, which consists of sixteen members: eight representing federal agencymanagement, and eight from labor organizations representing federal employees. In 2011,FACOSH evaluated the current OSH training requirements for federal employees. As part ofthis evaluation, FACOSH collected information from federal agencies and labororganizations representing federal employees regarding the OSH training needs of the federalworkforce. FACOSH analysis of the data resulted in a report, Recommendations forConsideration by the Secretary of Labor on Uniform Occupational Safety and HealthTraining Guidelines for the Federal Government, which included a series ofrecommendations for improving the consistency of OSH training requirements. In October2012, FACOSH submitted its report to the Secretary for consideration. Upon review,Secretary Hilda Solis approved the report and tasked OSHA with implementing theFACOSH recommendations.2. IntroductionAs part of its OSH program, each federal agency is responsible for providing appropriatetraining to ensure that employees have the knowledge and skills necessary to fulfill theirOSH obligations. The E.O. states that each agency head “shall provide safety and healthtraining for supervisory employees, employees responsible for conducting occupationalsafety and health inspections, all members of occupational safety and health committeeswhere established, and other employees.” The basic program elements in Part 1960, SubpartH also include several provisions addressing OSH training. The provisions in Part 1960 giveagency heads the flexibility necessary to implement their programs in a manner consistentwith their respective missions, sizes, and organizations.These guidelines summarize the OSH training requirements set forth in the Act, E.O., andbasic program elements. OSHA developed these guidelines to address the need for uniformOSH training at all staff levels of the Federal Government. The guidelines also state thatOSHA will issue notices of unsafe or unhealthful working conditions to federal agencies forviolations of the training requirements in Part 1960.Page 2 of 15

3. ReferencesOccupational Safety and Health Act of 1970, Section 19, Federal Agency Safety Programsand Responsibilities.Occupational Safety and Health Act of 1970, Section 6, Occupational Safety and HealthStandards.Executive Order 12196, Occupational Safety and Health Programs for Federal Employees,February 26, 1980.29 CFR Part 1960, Basic Program Elements for Federal Employee Occupational Safety andHealth Programs and Related Matters.Federal Advisory Council on Occupational Safety and Health Report, Recommendations forConsideration by the Secretary of Labor on Uniform Occupational Safety and HealthTraining Guidelines for the Federal Government, December 17, 2012.University of Wollongong, WHS Training Guidelines, April 2013.Office of Personnel Management, “Training Needs Assessment,” nd.4. DefinitionsAssessment is the process of documenting specific knowledge and skills, in measurableterms.Assessor is a person who evaluates an employee to determine his/her level of competence.Certified Safety and Health Committee is an agency safety and health committee thatmeets the provisions of section 1-3 of E.O. 12196 and 29 CFR Part 1960, verified by thehead of each federal agency in writing to the Secretary. These committees monitor and assistin carrying out the agency's safety and health policies and program at the workplaces undertheir jurisdiction.Collateral Duty Employees are employees who are assigned official occupational safety andhealth duties and responsibilities in addition to the primary duties and responsibilities of theposition the employee occupies.Competency describes the work-related skills and behavior needed to perform activities in asafe manner.Designated Agency Safety and Health Official (DASHO) is the individual who isresponsible for managing the safety and health program within an agency, and is sodesignated or appointed by the head of the agency pursuant to §1960.6 and the provisions ofExecutive Order 12196.Page 3 of 15

Employee is a person, other than members of the Armed Forces, employed or otherwisesuffered, permitted or required to work by an agency.Employee Representatives are representatives of agency employees as is consistent with theFederal Service Labor Management Relations Statute (5.U.S.C. 71), or collective bargainingor other labor management arrangements.Management Officials means a supervisor or management official as defined in theapplicable labor-management relations program covering the affected employees.Safety and Health Training is any activity provided to agency employees to help them gain,improve, or retain knowledge, skills, or abilities related to safety and health.Supervisory Employees are employees who exercise delegated authorities as defined by theU.S. Office of Personnel Management.Training Needs Assessment (TNA) is the process of identifying performance requirementsand the knowledge, skills, and abilities needed by an agency's workforce to achieve therequirements.5. ResponsibilitiesResponsibilities for OSH training are as follows:5.1Agency HeadThe agency head is responsible for providing top management officials withorientation and other learning experiences, which will enable them to manage theagency’s OSH program. The agency head is also responsible for assuring thatsafety and health officials are designated at each appropriate level with sufficientauthority and responsibility to plan for and secure funds for necessary safety andhealth staff, equipment, materials, and training required to ensure theimplementation of an effective occupational safety and health program.5.2Designated Agency Safety and Health Official (DASHO)DASHOs are responsible for their agency’s OSH program development andimplementation, as well as hazard recognition, evaluation and control, equipmentand facility design, standards, analysis of accident, injury, and illness data, andOSH training.5.3Management OfficialsManagement officials are responsible for ensuring that there are adequateresources and budgetary provisions for their agency’s OSH programs andinitiatives, including the necessary administrative costs for training and sufficientpersonnel to implement and administer the program at all levels.Page 4 of 15

6.5.4Supervisory EmployeesSupervisory employees are responsible for providing and maintaining safe andhealthful working conditions for employees. They are also responsible forensuring that staff completes OSH training. This includes training on theagency’s occupational safety and health program, occupational safety and healthstandards applicable to the agency’s workplaces, procedures for reportinghazards, procedures for reporting allegations of reprisal, and procedures for theabatement of hazards, as well as other appropriate rules and regulations.5.5Employee RepresentativesEmployee representatives are responsible for making certain that employeegroups function appropriately in ensuring safe and healthful working conditionsand practices in the workplace. This includes assisting the agency in conductingworkplace safety and health inspections.5.6Certified Safety and Health CommitteeEach certified safety and health committee is responsible for monitoring andassisting the agency’s safety and health program.5.7EmployeesEach agency employee should attend OSH training programs relevant to theirwork as directed by their supervisor.Skills, Knowledge and Training Requirements6.1OSH Skills and Knowledge Base (Competencies)OSH competencies are the skills and knowledge required for employees toperform work activities in a safe and healthful manner. To provide appropriateOSH training, it is necessary to identify competencies for each level ofresponsibility or role in the agency or department. Agencies should identifycompetencies by taking into account the work activities of the position or role andany risks associated with the conduct of these activities.The basic program elements in 29 CFR 1960, Subpart H, establishes the scope oftraining needs for six (6) different employee categories or groups. Specifically,sections 1960.54 through 1960.59 address OSH training for: top managementofficials; supervisors; safety and health specialists; safety and health inspectors;collateral duty employees and safety and health committee members; andemployees and employee representatives.There are specific OSH skills and knowledge that are common to all employeecategories. Employees should have an understanding of the general principlesand concepts included in the following documents, which provide a frameworkfor agencies’ safety and health programs: Section 19 of the Act;Page 5 of 15

E.O. 12196;29 CFR Part 1960; andAgency-specific OSH program.Categories of OSH competencies are as follows: General – General competencies are those that are identified according tothe agency’s function and OSH responsibility. These competencies arecommon to all employee categories (e.g., understanding the agency’sOSH program, including knowledge of employees’ rights andresponsibilities and methods for identifying and reporting workplacehazards, etc.). Risk-Specific – Risk-specific competencies are identified according to thetype of work being conducted (e.g., first aid, hazardous substanceawareness, ergonomics, etc.). Task-Specific – Task-specific competencies are the skills and knowledgeneeded by an employee in order to perform their work safely (e.g.,applying safe work procedures when operating a machine or piece ofequipment, etc.).6.2Training Needs AssessmentAgencies should conduct a Training Needs Assessment 1 (TNA) to identify andevaluate the safety and health training needs of the organization or an employee.The assessment should identify: What skills are required to perform the work activity;The agency requirements for safety and health training;The existing skill level of the staff performing the work; andWhether there is a training gap between the employee’s skill level and theskills needed to perform their work.Agencies and departments should identify generic and risk-specific OSHcompetencies using the following mechanisms: Legislative requirements;Review of employees’ injury/illness performance;Consultation with managers, supervisors, and/or employeerepresentatives; and1For additional information on Training Needs Assessments, please visit the Office of Personnel Management’swebsite: and-development/planning-evaluating.Page 6 of 15

Consultation with the certified safety and health committee.Employees should receive training that addresses their assigned responsibilities.Employees can work with their supervisor to identify the task-specificcompetencies. Once OSH training competencies are identified, the relevanttraining should be provided to achieve employee competency levels.Newly-identified generic and risk-specific competencies should be added to theOSH training program as they are identified.Agencies should use qualified personnel or safety and health experts within theiragency to conduct TNAs.6.3Specific Training RequirementsThe basic program elements at 29 CFR Part 1960, Subpart H, require that eachagency must provide the following training and learning experiences to specificemployee groups.A. Top Management OfficialsManagement officials must be provided with orientation and learningexperiences that will enable them to manage the occupational safety andhealth programs of their agencies. Such orientation should include therequirements of section 19 of the Act, E.O. 12196, 29 CFR Part 1960, andthe agency safety and health program.B. SupervisorsEach agency must provide supervisory employees with OSH training thatincludes: Supervisory responsibility for providing and maintaining safe andhealthful working conditions for employees;The agency OSH program (e.g., procedures for reporting andabating hazards, reporting and investigating allegations of reprisal,investigating accidents/incidents, reporting injuries and illnesses,etc.);Section 19 of the Act;E.O. 12196;29 CFR Part 1960;OSH standards applicable to the agency’s workplaces; andOther appropriate rules and regulations.Supervisory employees should be provided with learning experiences,including introductory and specialized courses and materials that willenable them to recognize and eliminate, or reduce occupational safety andPage 7 of 15

health hazards in their work units. Such training shall also include thedevelopment of required skills for managing the agency's safety and healthprogram within the work unit, including the training and motivation ofsubordinates to assure safe and healthful work practices.C. Safety and Health SpecialistsSafety and health specialists must receive training to prepare them toperform the necessary technical monitoring, consulting, testing,inspecting, designing, and other tasks related to program development andimplementation, as well as hazard recognition, evaluation and control,equipment and facility design, standards, analysis of accident, injury, andillness data, and other related tasks. Each agency should implement careerdevelopment programs for their occupational safety and health specialiststo enable the staff to meet present and future program needs of the agency.D. Safety and Health InspectorsEach agency must provide training for safety and health inspectors onapplicable agency standards, and the use of appropriate equipment andtesting procedures.E. Collateral Duty Staff and Certified Occupational Safety and HealthCommittee MembersOn appointment, collateral duty safety and health personnel and allmembers of certified occupational safety and health committees shouldreceive training that corresponds with the scope of their assignedresponsibilities. Such training should include agency procedures for thereporting, evaluation and abatement of hazards; agency procedures forreporting and investigating allegations of reprisal; the recognition ofhazardous conditions and environments; identification and use ofoccupational safety and health standards; and other appropriate rules andregulations.F. Employee RepresentativesEmployees that represent employee groups should receive OSH trainingthat includes both introductory and specialized courses and materials thatwill enable such groups to ensure safe and healthful working conditionsand practices in the workplace and enable them to assist in conductingworkplace safety and health inspections.G. EmployeesEmployees must receive appropriate safety and health training, includingspecialized job safety and health training, appropriate to the workperformed by the employee. Employees must also receive training on thePage 8 of 15

agency occupational safety and health program, with emphasis on theirrights and responsibilities.7. Training Programs7.1Develo

The E.O. states that each agency head “shall provide safety and health training for supervisory employees, employees responsible for conducting occupational safety and health inspections, all members of occupational safety and health committees where established, and other employees.” The basic program elements in Part 1960, Subpart

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