Who may conduct employee training?

There are many examples of standards that discuss training/employee information content, frequency, and/or documentation, but that do not specify any requirements for trainers. The permit-required confined space (PRCS) standard, 29 CFR 1910.146, that requires prompt rescue is one of these.

OSHA generally requires that trainers be competent or qualified to train other. While not explicitly stated in the PRCS standard, high hazard areas like this often fall into the qualified category. OSHA defines “Qualified” as meaning someone who, by possession of a recognized degree, certificate, or professional standing, or who by extensive knowledge, training, and experience, has successfully demonstrated his ability to solve or resolve problems relating to the subject matter, the work, or the project.

While OSHA doesn’t include specific qualifications for trainers, it remains the employer’s responsibility to ensure that employees are being adequately trained to meet the applicable standard’s requirements. As a good practice, the person who provides the training should have sufficient knowledge and experience to teach the trainees to properly use the necessary equipment and efficiently perform the anticipated procedures. The training program should include demonstrations and practice so that employees develop the skills they need to properly use the equipment and follow the procedures. The National Fire Protection Agency (NFPA) 1006 Standard for Technical Rescue Professional Qualifications has not been incorporated by reference by OSHA but does provide the foundation for rescue requirements for confined space in chapter 7.