The requirements for employers to document safety training is not something to take lightly because OSHA can ask for safety-related records at any time. Training records need to be kept up to date and be easily available—not only for OSHA but also for the employer’s benefit. Documentation helps organizations keep on top of trend analysis, organize material, pass on responsibilities, and lend support in case of liability/worker compensation claims.

It’s helpful to know the technical difference between documentation and certification. Documentation is the storage of necessary details for things like industrial hygiene reports, SDS and inspection records. Certification pertains mostly to training and contains information like who, when, where and what. Certificates only need to contain minimal information to note that training was done.  

Which training requires recordkeeping?

Depending on the training program, many OSHA standards require employee training and certification. Failure to document employee safety training to OSHA can lead to citations and fines.

Safety leaders should set up a recording system for all EHS training records and documents. This will ensure that the records are easy to retrieve and identify, and are maintained in an orderly fashion. Records should be kept current, accurate, legible and dated (including revision dates).

Certification requirements for different standards tend to be similar. Employers usually have to verify that an employee has received and understood safety training through written certification, which needs to contain the subject and date of training, the names of trained employees, the method and results of evaluation (with its date), the person performing the training or evaluation and their signature.

Here are the main standards that require certification of training:

• Hazardous waste operations (HAZWOPER) – this is required to be an authorized third-party certification
• Asbestos – this is required to be an authorized third-party certification
• Process safety management (PSM)
• Personal protective equipment (PPE)
• Permit-required confined spaces
• Lockout/tagout
• Logging – employers need to certify each employee in first aid and CPR
• Powered platforms
• Electric power generation, transmission and distribution
• Power press operators
• Powered industrial trucks
• Fall protection
• Telecommunications
• Cadmium

There is also the respiratory protection standard, which requires written documentation of medical evaluations, fit testing and training. For more details about each standard, OSHA lists training requirements in their publication Training Requirements in OSHA Standards.

Additional records

ANSI standards also recommend keeping records of the planning stage. This means that an employer should record the phase during which they create the training materials. These records should include: 

• target audience and learning objectives;
• sources used to develop training materials;
• people developing training materials, and their qualifications;
• all training materials used; and
• plans for evaluating (and improving) the course.

Keep records for all aspects of formal safety training, even when it’s not required—this could include future training dates and a summary of training content. This is useful because it can help to assess future training needs and keep track of employee progression through different programs.

How long to keep safety training records?

Training records should be kept for as long as an employee works for an organization. It might also be a good idea to keep them for a few more years after the employee leaves, as there is always a chance of them coming back.

The specific length of time that records should be kept may be mandated by legislation or regulations. In addition to legal requirements, training plans should also include procedures for document control.

Lastly, safety professionals should ask themselves some important questions about contractors. Do they have the required documentation? Does the company have copies? After all, just because they’re not regular employees doesn’t mean that they’re not required to ensure their records are in order.