OSHA 1910.120, Appendix A, 10 Suggested Training Plan Core Elements

OSHA’s Suggested Training Plan Core Elements

The following information was adapted from 29 CFR 1910.120 Appendix E, Training Curriculum Guidelines – (Non-mandatory). Although written specifically for training hazardous waste operations, the core criteria may serve as an excellent template for your safety training program’s design. In the next few sections, we will discuss the ten core criterias.

Training facility: The training facility should have sufficient resources available, equipment, and site locations to perform didactic and hands-on training when appropriate. Training facilities should have sufficient organization, support staff, and services to conduct training in each of the courses offered.Training Director: Each training program should be under the direction of a Training Director responsible for the program. The Training Director should have a minimum of two years of employee education experience.

Instructors: Instructors should be deemed competent based on:

• previous documented experience in their area of instruction,

• successful completion of a “train-the-trainer” program specific to the topics they will teach and

• an evaluation of instructional competence by the Training Director

Course materials: The Training Director should approve all course materials to be used by the training provider. Course materials should be reviewed and updated at least annually. Materials and equipment should be in good working order and maintained properly. All written and

audio-visual materials in the training curriculum should be peer-reviewed by technically competent outside reviewers or by a standing advisory committee.

Reviewers should possess expertise in the following disciplines where applicable: occupational health, industrial hygiene and safety, chemical/environmental engineering, employee education, or emergency response. One or more of the peer reviewers should be an employee experienced in the work activities directed in the training.

The program for accepting students should include:

• receive assurance that the student is or will be involved in work where exposures are likely and that the student possesses the skills necessary to perform the work; and

• provide a policy on the required medical clearance.

Ratios: Student-instructor ratios should not exceed 30 students per instructor. Hands-on activity requiring the use of personal protective equipment, testing equipment, or hazardous procedures should have instructor ratios of 5-10 students per instructor.

Proficiency assessment: Proficiency should be evaluated and documented using a written assessment and a skill demonstration selected and developed by the Training Director and training staff. The assessment and demonstration should evaluate the knowledge and individual skills developed in the course of training. It’s important to understand that “individual,” not “group” testing should be accomplished. Asking the “group” questions and receiving answers from one or more group members, is not acceptable.

The level of minimum achievement necessary for proficiency should be specified in writing by the Training Director as follows:

• If a written test is used, there should be a minimum of 20-30 questions. Each student should answer all questions, and a minimum test score of 70% should be required.

• If a skills demonstration is used, the Training Director should fully document the tasks chosen and the means to rate successful completion.

The content of the written test or skill demonstration must be relevant to the objectives of the course. The written test and skill demonstration should be updated to reflect changes in the curriculum, and the Training Director should review and approve any updates.

Regardless of the approach or combination of approaches used, the Training Director should justify, document, and approve the proficiency assessment methods. The proficiency of those taking the additional courses for supervisors should be evaluated and documented by using proficiency assessment methods accepted by the Training Director. These proficiency assessment methods must reflect the additional responsibilities of supervisory personnel in hazardous waste operations or emergency response.

Course certificate: Each student who satisfactorily completes the training course should be provided with written documentation. Certificates and cards provide a permanent record of your training achievements and should be kept in the employee’s possession.

The documentation should include:

• student name;

• course title;

• course completion date;

• a statement that the student has successfully completed the course;

• name and address of the training provider;

• an individual identification number for the certificate; and

• list of personal protective equipment authorized for use (if required).

This documentation may include a certificate and an appropriate wallet-sized card of the above information. When such course certificate cards are used, the training certificate’s individual identification number should be shown on the card.

Recordkeeping: Training providers should maintain records listing the dates courses were presented, the names of the individual course attendees, the names of those students successfully completing each course, and the number of training certificates issued to each successful student. These records should be:

• maintained for a minimum of five years after the date an individual participated in a training program offered by the training provider, and

• available and provided upon the student’s request or as mandated by law.

Program quality control: The Training Director should conduct or direct an annual written audit of the training program.

• The Training Provider should document, approve, and implement any program modifications to address deficiencies.

• The audit and the program modification documents should be maintained at the training facility.

Download the complete CFR 29 1910.120, Appendix E.

Download a Sample Training Plan (pdf format).