May 2007 - OSHA Training Standards Policy Statement

The Occupational Safety and Health Administration (OSHA) has published a standard interpretation dealing with worker training that applies to all of the Agency's agriculture, construction, general industry, and maritime training requirements. Some highlights from the policy statement include:

Many OSHA standards require that employees receive training so that work will be performed in a safe and healthful manner. Some of these standards require "training" or "instruction," others require "adequate" or "effective" training or instruction, and still others require training "in a manner" or "in language" that is understandable to employees. It is the Agency's position that, regardless of the precise regulatory language, the terms "train" and "instruct," as well as other synonyms, mean to present information in a manner that employees receiving it are capable of understanding.

In practical terms, this means that an employer must instruct its employees using both a language and vocabulary that the employees can understand. For example, if an employee does not speak or comprehend English, instruction must be provided in a language the employee can understand. Similarly, if the employee's vocabulary is limited, the training must account for that limitation. By the same token, if employees are not literate, telling them to read training materials will not satisfy the employer's training obligation. As a general matter, employers are expected to realize that if they customarily need to communicate work instructions or other workplace information to employees at a certain vocabulary level or in a language other than English, they will also need to provide safety and health training to employees in the same manner. Of course, employers may also provide instruction in learning the English language to non-English speaking employees. Over time, this may lessen the need to provide OSH Act training in other languages.

The interpretation also addresses links to Spanish-language information and OSHA compliance officer responsibilities. This new interpretation covering OSHA standards 1910.134(k)(5)(ii), 1910.147(c)(7)(i), and 1910.1030(g)(2)(vii)(N), may be found on the OSHA Web site at http://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=INTERPRETATIONS&p_id=25658.

COPYRIGHT ©2007, ISO Services Properties, Inc.

The information contained in this publication was obtained from sources believed to be reliable. ISO Services Properties, Inc., its companies and employees make no guarantee of results and assume no liability in connection with either the information herein contained or the safety suggestions herein made. Moreover, it cannot be assumed that every acceptable safety procedure is contained herein or that abnormal or unusual circumstances may not warrant or require further or additional procedure.