Proving training is not something you can do at the last moment after an OSHA inspector shows up. "Trying to pull together the training records is very difficult after the fact," warns a Georgia lawyer. You need a proactive strategy to document key information about each training session. A training log should be a big part of that strategy. Let's talk about how to create one. There's also a model form that you can adapt in the Tools section of SafetyXChange.

The Advantages of Keeping a Training Log

In addition to documenting compliance with training requirements, keeping a training log can help you:

Cut Injuries. Having a written record showing the training each worker has received and when enables you to check if workers are qualified to do the jobs you assign them. This is important because it's easy to lose track of what jobs an individual worker has been trained to perform. You can also use the logs to diagnose hazards or patterns of injury more effectively. For example, if a series of incident occurs, you may discover by analyzing the training logs that all of the victims were trained by the same foreman and that you need to relieve the foreman of further training duties.

Comply With Retraining Requirement. OSHA requires you to retrain each worker periodically (say, every year or three years, depending on the standard). You must also retrain workers before they begin a new job. Employers may forget about retraining or lose track of when they last provided the worker training. Training logs can help avoid these mistakes because they show when initial training was provided and when retraining is due.

Document Certification. Some OSHA standards, such as Personal Protective Equipment and Powered Platforms, require verification of training. There has to be a written certification of training for each worker. To prepare this certification, you must have a written record of who was trained, on what date and by whom. This is where training logs can make a huge difference. Even though the actual certification goes to the worker, you need to keep a record of the information it's based on for your files.

How to Create a Training Log

A training log doesn't have to be elaborate. But it does have to capture the right information. Like the Model Form in Tools, your training log should include:

• The worker's name;
• The subject of each training session;
• The dates of each training session;
• The dates of each retraining session;
• Signatures or initials of each trainer; and
• Whether the worker received a certification required by the OSHA standards.

How to Use Your Training Log

Once you create the log, have your supervisors fill out a separate training form for each of their workers. Each time they create or update a training form, they should keep the original and send a copy to:

• The safety director, to keep in a central employee safety training file; and
• The personnel department, to keep in the worker's personnel file.

This should ensure that your logs are complete and on hand when and if an OSHA inspector demands to see them.

Conclusion

In two weeks, on June 4, we'll resume our discussion with a look at the second key phase of the training compliance process: verifying and documenting the effectiveness of your training programs.

ASK OSHA

Recordkeeping: Date of Injury for Carpal Tunnel

By Glenn Demby

SITUATION

A worker in a job involving repetitive stress complains to the company about wrist pain on Nov. 15, 2006. He gets first aid treatment and goes back to work. His pain gradually gets worse. On Feb. 15, 2007, the worker sees a doctor and is diagnosed with bilateral carpal tunnel syndrome and starts treatment. Six months later, he needs surgery for the condition and misses work as a result.

QUESTION

Which date should the company list in column D (date of injury or onset of illness) in the OSHA 300 Log - Nov. 15, 2006 or Feb. 15, 2007?

ANSWER

Feb. 15, 2007.

EXPLANATION

According to an FAQ (29-5) at the end of the OSHA Recordkeeping Policies and Procedures Manual, if a worker first reports a problem in Year 1 but doesn't get diagnosis or treatment until Year 2, the injury should be reported "when the injury occurred." If you don't know the date, the FAQ says use the date the worker first reported the symptoms. That would seem to suggest reporting the date of injury as Nov. 15.

But OSHA says that the FAQ in the Manual assumes "a single, recordable injury or report of symptoms," rather than a "series of aggravating events or exposures over time." In this case, OSHA says, you'd list Nov 06 - the date the worker first reported the injury - only if you're sure that there was no aggravating event or exposure in the workplace after Nov. 15 that contributed to the injury. If you can't be sure of that, list the date of injury as Feb. 15, 2007.

Source: OSHA Interpretation Letter, Nov. 30, 2004

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