We all have heard the old saying, “if it isn’t documented, it didn’t happen.”
This saying isn’t necessarily true, but the statement makes a valid case for effective safety training documentation. While the primary reason for delivering and documenting training is to help protect employees, safety leaders also must protect the employer during regulatory inspections and litigation. Effective training documentation can provide evidence of the employer’s good faith efforts toward complying with training requirements defined by the Occupational Safety and Health Administration (OSHA).
While many OSHA standards require training, many do not require that the training be documented. However, several general industry standards require training documentation:
Many standards reference training but do not have specific language regarding training documentation requirements. Should an OSHA compliance officer inspect an employer’s facility, he or she most likely will look for evidence that safety training is provided for standards requiring training documentation and possibly those that do not.
The most effective way to establish fulfillment of training requirements is to document all employee safety. The inspector may verify training by reviewing training documentation records or through employee interviews. If an employee indicates during the interview process that he or she was not trained, and there is no documentation to disprove this claim, a citation may be issued.
It is also important to understand that several standards require annual refresher training or additional training should new hazards be introduced into the work environment. For example, OSHA’s Hazard Communication Standard requires additional training “whenever a new chemical hazard the employees have not been previously trained about is introduced into their work area.” This type of training also should be documented.
Many employers rely on various forms of training to comply with OSHA standards and company requirements. These forms include classroom training, online training, hands-on or skills-based training, or any combination of these methods.
At a minimum, classroom training documentation should include a description of the subject matter, the date, the names of the attendees, and the name of the instructor. In addition to these basic requirements, consider requiring a signature alongside the printed name of the attendee and instructor, a description of any materials used including references to videos, online content, handouts, presentations, hands-on exercises, and conversations specific to company requirements.
In addition to classroom, hands-on, and online training delivery, many companies utilize routine “toolbox” or pre-shift safety meetings to discuss and review specific safety requirements prior to performing routine and non-routine tasks. These types of informal meetings generally are conducted to raise general awareness and elevate employee focus on safety and health.
Toolbox talks are not required by OSHA; however, many safety professionals and companies encourage and require these forms of training and their documentation. Employers are encouraged to document toolbox talks in the same manner that classroom training is documented. Documented toolbox talks can be used to supplement training required by OSHA delivered in a classroom or online.
A few years ago I attended a workplace safety symposium. An administrative law judge discussed several cases that he had presided over and provided the group with some recommendations for complying with OSHA standards, specifically the training component.
He indicated that over his lengthy career, many cases were decided based on the effectiveness of employee training. He specifically indicated that on many occasions, employees were shown videos, sometimes over the lunch hour, where a sign-in sheet was used to document the training.
He expressed concern over the timing of the delivery and lack of testing to ensure comprehension. He also referenced the value of testing not only as an additional form of documentation, but also proof of comprehension and understanding of the topic. He referenced both written tests associated with classroom training and the testing provided within online learning management systems as effective ways to demonstrate comprehension of the subject matter.
OSHA also requires that training should be provided in a manner that employees can understand easily. Successfully passing a test demonstrates that the training subject matter was delivered in this manner.
Training documentation is a critical element of an employer’s safety program. Evaluate the documentation process and records at your facility, and ensure that the system is effective. Document all safety training, regardless of whether it is required or not, and consider using hands-on evaluation or testing to ensure employee comprehension and understanding of the subject matter. This approach will be beneficial during OSHA inspections and incidents involving litigation.
The old saying still holds true, “if it isn’t documented, it didn’t happen.”
Joe Mlynek is president and safety and loss control consultant for Progressive Safety Services LLC, Gates Mills, OH; 216-403-9669; and content creation expert for Safety Made Simple, Olathe, KS.
To view Joe Mlynek’s Safety Webinars, go to
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Reprinted from Grain Journal March/April 2017 Issue