How long do I have to retain records for employee training?

There is no one OSHA requirement for training records that applies in all situations. Training recordkeeping requirements vary from regulation to regulation. In some cases, OSHA sets a record retention time or specifies requirements for the contents of training records, but this is not always the case. When training records are required, it would be best to always have them available.

A good practice would be to keep all training records during the worker’s full period of employment. Even if a rule does not specifically require a record retention time, your company may want to 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.

KellerOnline’s Learning Center Area has a workplace safety Best Practice on Safety Training Records that may be of interest to you. And, KellerOnline’s Interactive Tools area has a section on Recordkeeping Programs that allows you to use KellerOnline to keep your Employee/Training records electronically. KellerOnline’s Reference area includes a document called Training Requirements at a Glance that summarizes federal OSHA’s general industry training requirements.

Here are some examples of OSHA training record requirements:

• 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.
• Hazard communication (1910.1200) — requires retraining as new hazards are introduced, but no specific written training record is required.
• 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. OSHA does not set a record retention time.
• 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. OSHA does not set a record retention time.
• 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. OSHA does not set a record retention time.
• 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. OSHA does not set a record retention time.
• Process safety management (1910.119) — requires retraining at least every 3 years and a written training record. No training record retention time is specified.
• Respiratory protection (1910.134) — no specific written training record is required. Written fit testing records must be retained until the next test takes place.