Before engaging in any potentially hazardous activities, workers must receive appropriate safety training from their employer, as defined in OSHA standards.
Scope
There is no one OSHA general industry requirement for training records or their retention. Any requirements for training records will be found in each individual regulation. In many cases, OSHA requires employers to maintain training records, but no record retention time is specified.
Key definitions
- Training record: A file that documents training an employee received. Most often, this includes the employee’s name, signature, and date of training.
Summary of requirements
Examples of general industry rules that have training record requirements include:
- Asbestos (1910.1001) - Employers are to maintain training records for one year beyond an employee’s last date of employment.
- Bloodborne pathogens (1910.1030) - Training records must include dates of training, contents of training sessions, names and qualifications of trainers, and names and job titles of those trained. Records must be retained for three years.
- Cadmium (1910.1027) - The employer is to prepare a certification record of training that includes the employee’s name, signature of the employer or the trainer, and date of training. This record is to be maintained for one year beyond the training date.
- Hazardous waste operations and emergency response (HAZWOPER) (1910.120) - Under the emergency response requirements at 1910.120(q), employers must maintain a statement of training or competency. Under the requirements for hazardous waste site employees (1910.120(e)) and treatment, storage, and disposal facilities (1910.120(p)), a written training certificate must be given to each person who has completed the training.
- Lockout/tagout (1910.147) - The training certification must contain each employee’s name and the dates of training.
- Logging operations (1910.266) - The written certification record must contain the name or other identity of the employee trained, the dates of the training, and the signature of the person who conducted the training or the signature of the employer.
- Permit-required confined spaces (1910.146) - Training certifications must include each employee’s name, the signatures or initials of the trainers, and the dates of training.
- Personal protective equipment (1910.132) - The training certificate must include the employee’s name, the date, and the subject of the training. Employees must be able to demonstrate an understanding of the training.
- Powered industrial trucks (1910.178) - The employer must certify that the operator has been trained and evaluated. The certification must include the operator’s name, the dates of the training and evaluation, and the name of the trainer/evaluator.
- Powered platforms for building maintenance (1910.66) - The training certificate must include the employee’s name, the signature of the employer or the trainer, and the date of the training. Training records must be kept for the duration of the employee’s employment.
- Process safety management (1910.119) - Training records must include the employee’s identity, the date of training, and the means used to verify that the employee understood the training.
- Telecommunications (1910.268) - The training certification must include the identity of the person trained, the signature of the employer or the person who conducted the training, and the date the training was completed. The training certification record must be retained for the duration of employment.
When training records are required, it is best to always have them available. Consider keeping all training records during the worker’s full period of employment. Your company may even set a policy to retain training records for a period after employment has been terminated.
When written training records are not required, your company may still want to prepare them as a way to help keep your safety training program organized.
