Is it required to have a hard copy of signatures on file for OSHA mandated training?

It is a common industry practice to take attendance of all employees who attended training sessions; however, OSHA does not require signatures from employees who have attended training sessions.

However, certain OSHA standards, such as the Personal Protective Equipment standard, 29 CFR 1910.132, require verification, through a written certification, that each affected employee has received and understood the required training. The written certification must contain the name of each employee trained, the date(s) of training, and identify the subject of the certification.

Concerning the use of electronic signatures to certify training, OSHA issued a letter of interpretation on this subject on April 10, 2000. When a rule specifies that training records contain a signature, you would need to have a hard copy of the training record including the signature if electronic records are not capable of recording an electronic signature.