What does OSHA mean by “at least annually” with regard to training frequency?

Wherever standards require that employee training be conducted “at least annually,” OSHA interprets that to mean that employees must be provided retraining at least once every 12 months (i.e., within a time period not exceeding 365 days.) However, this annual training need not be performed on the exact anniversary date of the preceding training, but should be provided on a date reasonably close to the anniversary date taking into consideration the company’s and the employees’ convenience in scheduling. If the annual training cannot be completed by the anniversary date, the employer should maintain a record indicating why the training has been delayed and when the training will be provided, OSHA says. Keep in mind that the term “at least annually” is generally regarded as indicating that circumstances which warrant more frequent training may occur. It is extremely important that employees are trained to protect themselves from all known workplace hazards, including new hazards which may result from changes in workplace practices, procedures, or tasks. For example, OSHA’s Bloodborne Pathogens Standard provides for “additional training when changes such as modification of tasks or procedures or institution of new tasks or procedures affect the employee’s occupation exposure.” More frequent training may also be required when employee performance suggests that the prior training was incomplete or not fully understood. Reference: January 24, 2007 OSHA Letter of Interpretation