OSHA ANNUAL TRAINING REQUIREMENTS
The Occupational Safety and Health Administration (OSHA) creates and enforces environmental, health and safety (EHS) standards for U.S. workers. Many of these standards come with specific training requirements, which OSHA has published in its Training Requirements in OSHA Standards, available free online.
Some OSHA standards stipulate annual training requirements. We have compiled a listing below of the topics that OSHA has established annual training requirements. For each entry, we have included the regulatory reference and the quoted verbiage that contains the annual requirement. This information may be used in planning your training programs. However, specific application of the standards may vary, so it is recommended that you read the standards that apply to you or your workers in their entirety before implementing training decisions.
OSHA standards are published for General Industry (29 CFR 1910), Construction Industry (29 CFR 1926), Shipyard Employment (29 CFR 1915) and Agriculture (29 CFR 1928). The references below are categorized by industry.
GENERAL INDUSTRY
Occupational Noise Exposure
29 CFR 1910.95 (k)(2) – “The training program shall be repeated annually for each employee included in the hearing conservation program. In formation provided in the training program shall be updated to be consistent with changes in protective equipment and work processes.”
Hazardous Waste Operations and Emergency Response
29 CFR 1910.120 (e) (1) (8) – “Refresher training. Employees specified in paragraph (e)(1) of this section, and managers and supervisors specified in paragraph (e) (4) of this section, shall receive eight hours of refresher training annually on the items specified in paragraph (e)(2) and/or (e)(4) of this section, critiques of incidents that have occurred in the past year that can serve as training examples of any related work, and other relevant topics.”
29 CFR 1910.120 (e) (7) (i) – “New employees. The employer shall develop and implement a training program, which is part of the employer’s safety and health program, for employees exposed to health hazards or hazardous substances at TSD operations to enable the employees to perform their assigned duties and functions in a safe and healthful manner so as not to endanger themselves or other employees. The initial training shall be for 24 hours and refresher training shall be for eight hours annually. Employees who have received the initial training required by this paragraph shall be given a written certificate attesting that they have successfully completed the necessary training.”
29 CFR 1910.120 (e) (7) (ii) – “Current employees. Employers who can show by an employee’s previous work experience and/or training that the employee has had training equivalent to the initial training required by this paragraph, shall be considered as meeting the initial training requirements of this paragraph as to that employee. Equivalent training includes the training that existing employees might have already received from actual site work experience. Current employees shall receive eight hours of refresher training annually.”
29 CFR 1910.120 (q) (5) – “Specialist employees. Employees who, in the course of their regular job duties, work with and are trained in the hazards of specific hazardous substances, and who will be called upon to provide technical advice or assistance at a hazardous substance release incident to the individual in charge, shall receive training or demonstrate competency in the area of their specialization annually.”
29 CFR 1910.120 (q) (8) (i) – “Those employees who are trained in accordance with paragraph (q)(6) of this section shall receive annual refresher training of sufficient content and duration to maintain their competencies or shall demonstrate their competency in those areas at least yearly.”
Appendix C to 1910.120 – Compliance Guidelines
Training – “The training programs for employees subject to the requirements of paragraph (p) of this standard should address:
the employer’s safety and health program elements impacting employees;
the hazard communication program;
the medical surveillance program;
the hazards and the controls for such hazards that employees need to know for their job duties and functions.
All require annual refresher training.”
Appendix C to 1910.120 – Compliance Guidelines
Training – “Specialist employees such as technical experts, medical experts or environmental experts that work with hazardous materials in their regular jobs, who may be sent to the incident scene by the shipper, manufacturer or governmental agency to advise and assist the person in charge of the incident should have training on an annual basis. Their training should include the care and use of personal protective equipment including respirators; knowledge of the incident command system and how they are to relate to it; and those areas needed to keep them current in their respective field as it relates to safety and health involving specific hazardous substances.”
Appendix E to 1910.120 — Training curriculum guidelines
Instructors – “Instructors should be required to maintain professional competency by participating in continuing education or professional development programs or by completing successfully an annual refresher course and having an annual review by the Training Director.”
Course materials – “Course materials should be reviewed and updated at least annually.”
Respiratory Protection
29 CFR 1910.134 (k) (1) Training and information – “This paragraph requires the employer to provide effective training to employees who are required to use respirators. The training must be comprehensive, understandable, and recur annually, and more often if necessary.”
29 CFR 1910.134 (k) (5) – “Retraining shall be administered annually and when the following situations occur: (i) Changes in the workplace or the type of respirator render previous training obsolete; (ii) Inadequacies in the employee’s knowledge or use of the respirator indicate that the employee has not retained the requisite understanding or skill; or (iii) Any other situation arises in which retraining appears necessary to ensure safe respirator use.”
The Control of Hazardous Energy (Lockout/Tagout)
29 CFR 1910.147 (6)(i) – “The employer shall conduct a periodic inspection of the energy control procedure at least annually to ensure that the procedure and the requirements of this standard are being followed.”
29 CFR 1910.147 (7)(iii)(B) – “) Additional retraining shall also be conducted whenever a periodic inspection under paragraph (c) (6) of this section reveals, or whenever the employer has reason to believe, that there are deviations from or inadequacies in the knowledge or use of the energy control procedures.”
While there is no inherent requirement for annual retraining in the LOTO standard, it does require an annual inspection of the LOTO procedure used by the employer. If that periodic inspection shows that there are gaps in worker knowledge, or if the employer believes there are gaps in worker knowledge regarding LOTO procedures, then retraining is required.
Fire Brigades
29 CFR 1910.156 (c)(2) – “The employer shall assure that training and education is conducted frequently enough to assure that each member of the fire brigade is able to perform the member’s assigned duties and functions satisfactorily and in a safe manner so as not to endanger fire brigade members or other employees. All fire brigade members shall be provided with training at least annually. In addition, fire brigade members who are expected to perform interior structural firefighting shall be provided with an education session or training at least quarterly.”
Portable Fire Extinguishers
29 CFR 1910.157 (g)(1) – “Where the employer has provided portable fire extinguishers for employee use in the workplace, the employer shall also provide an educational program to familiarize employees with the general principles of fire extinguisher use and the hazards involved with incipient stage firefighting.”
(2) – “The employer shall provide the education required in paragraph (g)(1) of this section upon initial employment and at least annually thereafter.”
Fixed Extinguishing Systems
29 CFR 1910.160 (b) (10) – “The employer shall train employees designated to inspect, maintain, operate, or repair fixed extinguishing systems and annually review their training to keep them up-to-date in the functions they are to perform.”
Machinery and Machine Guarding
29 CFR 1910.217 (e) (3) – “Training of maintenance personnel. It shall be the responsibility of the employer to insure the original and continuing competence of personnel caring for, inspecting, and maintaining power presses.”
29 CFR 1910.217 (h) (13) (i) – “The operator training required by paragraph (f)(2) of this section shall be provided to the employee before the employee initially operates the press and as needed to maintain competence, but not less than annually thereafter.”
Logging
29 CFR 1910.266 (i) (7) (ii) – “The employer shall assure that each employee receives first-aid training at least every three years and receives CPR training at least annually.”
Electric Power Generation, Transmission, and Distribution
29 CFR 1910.269 (a) (iii) – “The employer shall determine, through regular supervision and through inspections conducted on at least an annual basis, that each employee is complying with the safety-related work practices required by this section.”
29 CFR 1910.269 (a) (iv) (A)(B)(C) – “(A) If the supervision and annual inspections required by paragraph (a)(2)(iii) of this section indicate that the employee is not complying with the safety-related work practices required by this section, or (a)(2); (b)(1); (d)(2)(vi) through (viii) Training Requirements in OSHA Standards 75 Training Requirements (B) If new technology, new types of equipment, or changes in procedures necessitate the use of safety-related work practices that are different from those which the employee would normally use, or (C) If he or she must employ safety-related work practices that are not normally used during his or her regular job duties.”
While there is no inherent requirement for annual retraining in the Electric Power Generation, Transmission and Distribution standard, it does require an annual inspection of safety-related procedures. If that periodic inspection shows that there are gaps in worker knowledge, then retraining is required.
Grain Handling Facilities
29 CFR 1910.272 (e) (1) – “The employer shall provide training to employees at least annually and when changes in job assignment will expose them to new hazards.”
Asbestos
29 CFR 1910.1001 (j) (7) (ii) – “Training shall be provided prior to or at the time of initial assignment and at least annually thereafter.”
13 Carcinogens
29 CFR 1910.1003 (e)(4)(i)(I) – “A review of this section at the employee’s first training and indoctrination program and annually thereafter.”
Vinyl Chloride
29 CFR 1910.1017 (j)(ix) – “A review of this standard at the employee’s first training and indoctrination program, and annually thereafter.”
Inorganic Arsenic
29 CFR 1910.1018 (o)(1)(ii) – “The training program shall be provided by October 1, 1978, for employees covered by this provision, at the time of initial assignment for those subsequently covered by this provision, and at least annually for other covered employees thereafter;”
Lead
29CFR 1910.1025 (l)(1)(iv) – “The training program shall be repeated at least annually for each employee.”
Cadmium
29 CFR 1910.1027 (m)(4)(ii) – “Training shall be provided prior to or at the time of initial assignment to a job involving potential exposure to cadmium and at least annually thereafter.”
Benzene
29 CFR 1910.1028 (j)(3)(i) – “The employer shall provide employees with information and training at the time of their initial assignment to a work area where benzene is present. If exposures are above the action level, employees shall be provided with information and training at least annually thereafter.”
Coke Oven Emissions
29 CFR 1910.1029 (k)(l)(iii) – “The training program shall be provided at least annually for all employees who are employed in the regulated area, except that training regarding the occupational safety and health hazards associated with exposure to coke oven emissions and the purpose, proper use, and limitations of respiratory protective devices shall be provided at least quarterly until January 20, 1978.”
Bloodborne Pathogens
29 CFR 1910.1030 (g)(2)(i)(ii) – “The employer shall train each employee with occupational exposure in accordance with the requirements of this section. Such training must be provided at no cost to the employee and during working hours. The employer shall institute a training program and ensure employee participation in the program. (ii) Training shall be provided as follows: (A) At the time of initial assignment to tasks where occupational exposure may take place; (B) At least annually thereafter.”
Cotton Dust
29 CFR 1910.1043 (i)(l)(ii) – “The training program shall be provided prior to initial assignment and shall be repeated annually for each employee exposed to cotton dust, when job assignments or work processes change, and when employee performance indicates a need for retraining.”
Acrylonitrile (vinyl cyanide)
29 CFR 1910.1045 (o)(1)(ii) – “Training shall be provided at the time of initial assignment, or upon institution of the training program, and at least annually thereafter…”
Ethylene Oxide
29 CFR 1910.1047 (j)(3)(i) – “The employer shall provide employees who are potentially exposed to EtO at or above the action level or above the excursion limit with information and training on EtO at the time of initial assignment and at least annually thereafter.”’
Formaldehyde
29 CFR 1910.1048 (n)(2) – “Frequency. Employers shall provide such information and training to employees at the time of initial assignment, and whenever a new exposure to formaldehyde is introduced into the work. The training shall be repeated at least annually.”
Methylenedianiline
29 CFR 1910.1050 (k)(3)(i) – “The employer shall provide employees with information and training on MDA in accordance with 29 CFR 1910.1200(h) at the time of initial assignment and at least annually thereafter.”
1,3-Butadiene
29 CFR 1910.1051 (I)(2)(iii) – “Training shall be provided prior to or at the time of initial assignment to a job potentially involving exposure to BD at or above the action level or STEL and at least annually thereafter.”
Respiratory Protection (General Industry and Construction Industry)
29 CFR 1910.134 (k) – “Training and information. This paragraph requires the employer to provide effective training to employees who are required to use respirators. The training must be comprehensive, understandable, and recur annually, and more often if necessary. This paragraph also requires the employer to provide the basic information on respirators in Appendix D of this section to employees who wear respirators when not required by this section or by the employer to do so.
29 CFR 1910.134 (k)(5) – “Retraining shall be administered annually, and when the following situations occur: (i) Changes in the workplace or the type of respirator render previous training obsolete; (ii) Inadequacies in the employee’s knowledge or use of the respirator indicate that the employee has not retained the requisite understanding or skill; or (iii) Any other situation arises in which retraining appears necessary to ensure safe respirator use.”
29 CFR 1926.103 – “[Note: The requirements applicable to construction work under this section are identical to those set forth at 29 CFR 1910.134 of this chapter.]”
SHIPYARD EMPLOYMENT
Fire Protection (Shipyard Employment)
29 CFR 1915.508 (e)(1) – “The employer must ensure that each fire watch is trained by an instructor with adequate fire watch knowledge and experience to cover the items as follows: (i) Before being assigned to fire watch duty; (ii) Whenever there is a change in operations that presents a new or different hazard; (iii) Whenever the employer has reason to believe that the fire watch’s knowledge, skills, or understanding of the training previously provided is inadequate; and (iv) Annually.”
Asbestos (Shipyard Employment)
29 CFR 1915.1001 (k)(9)(ii) – “Training shall be provided prior to or at the time of initial assignment and at least annually thereafter.”
CONSTRUCTION INDUSTRY
Methylenedianiline (Construction Industry)
29 CFR 1926.60 (1)(3)(i) – “The employer shall provide employees with information and training on MDA, in accordance with 29 CFR 1910.1200(h), at the time of initial assignment and at least annually thereafter.”
Lead (Construction Industry)
29 CFR 1926.62 (1)(iv) – “The employer shall also provide the training program at least annually for each employee who is subject to lead exposure at or above the action level on any day.”
Hazardous Waste Operations and Emergency Response (Construction Industry)
29 CFR 1926.65 (e)(1)(8) – “Refresher training. Employees specified in paragraph (e)(1) of this section, and managers and supervisors specified in paragraph (e) (4) of this section, shall receive eight hours of refresher training annually on the items specified in paragraph (e)(2) and/or (e)(4) of this section, any critique of incidents that have occurred in the past year that can serve.”
29 CFR 1926.65 (p)(7)(i) – “New employees. The employer shall develop and implement a training program, which is part of the employer’s safety and health program, for employees exposed to health hazards or hazardous substances at TSD operations to enable the employees to perform their assigned duties and functions in a safe and healthful manner so as not endanger themselves or other employees. The initial training shall be for 24 hours and refresher training shall be for eight hours annually. Employees who have received the initial training required by this paragraph shall be given a written certificate attesting that they have successfully completed the necessary training.”
29 CFR 1926.65 (p)(7)(ii) – “Current employees. Employers who can show by an employee’s previous work experience and/or training that the employee has had training equivalent to the initial training required by this paragraph, shall be considered as meeting the initial training requirements of this paragraph as to that employee. Equivalent training includes the training that existing employees might have already received from actual site work experience. Current employees shall receive eight hours of refresher training annually.”
29 CFR 1926.65 (q)(5) – “Specialist employees. Employees who, in the course of their regular job duties, work with and are trained in the hazards of specific hazardous substances, and who will be called upon to provide technical advice or assistance at a hazardous substance release incident to the individual in charge, shall receive training or demonstrate competency in the area of their specialization annually.”
29 CFR 1926.65 (q)(8) – “Those employees who are trained in accordance with paragraph (q)(6) of this section shall receive annual refresher training of sufficient content and duration to maintain their competencies, or shall demonstrate competency in those areas at least yearly.”
Appendix C to 1926.65 – Compliance Guidelines (Construction Industry)
Training – “The training programs for employees subject to the requirements of paragraph (e) of this standard should address: the safety and health hazards employees should expect to find on hazardous waste clean-up sites; what control measures or techniques are effective for those hazards; what monitoring procedures are effective in characterizing exposure levels; what makes an effective employer’s safety and health program; what a site safety and health plan should include; hands on training with personal protective equipment and clothing they may be expected to use; the contents of the OSHA standard relevant to the employee’s duties and function; and, employee’s responsibilities under OSHA and other regulations. Supervisors will need training in their responsibilities under the safety and health program and its subject areas such as the spill containment program, the personal protective equipment program, the medical surveillance program, the emergency response plan and other areas. 176 Training Requirements in OSHA Standards Construction The training programs for employees subject to the requirements of paragraph (p) of this standard should address: the employer’s safety and health program elements impacting employees; the hazard communication program; the medical surveillance program; the hazards and the controls for such hazards that employees need to know for their job duties and functions. All require annual refresher training.
…
Specialist employees such as technical experts, medical experts or environmental experts that work with hazardous materials in their regular jobs, who may be sent to the incident scene by the shipper, manufacturer or governmental agency to advise and assist the person in charge of the incident should have training on an annual basis. Their training should include the care and use of personal protective equipment including respirators; knowledge of the incident command system and how they are to relate to it; and those areas needed to keep them current in their respective field as it relates to safety and health involving specific hazardous substances.
…
Suggested Core Criteria:
Instructors should be deemed competent on the basis of previous documented experience in their area of instruction, successful completion of a “train-the-trainer” program specific to the topics they will teach, and an evaluation of instructional competence by the Training Director. Instructors should be required to maintain professional competency by participating in continuing education or professional development programs or by completing successfully an annual refresher course and having an annual review by the Training Director. The annual review by the Training Director should include observation of an instructor’s delivery, a review of those observations with the trainer, and an analysis of any instructor or class evaluations completed by the students during the previous year.
Course materials: Course materials. The Training Director should approve all course materials to be used by the training provider. Course materials should be reviewed and updated at least annually. Materials and equipment should be in good working order and maintained properly. All written and audio-visual materials in training curricula should be peer reviewed by technically competent outside reviewers or by a standing advisory committee. Reviews should possess expertise in the following disciplines were applicable: occupational health, industrial hygiene and safety, chemical/environmental engineering, employee education, or emergency response. One or more of the peer reviewers should be an employee experienced in the work activities to which the training is directed.
Program Quality Control. The Training Director should conduct or direct an annual written audit of the training program. Program modifications to address deficiencies, if any, should be documented, approved, and implemented by the training provider. The audit and the program modification documents should be maintained at the training facility.
Respiratory Protection (General Industry and Construction Industry)
29 CFR 1910.134 (k) – “Training and information. This paragraph requires the employer to provide effective training to employees who are required to use respirators. The training must be comprehensive, understandable, and recur annually, and more often if necessary. This paragraph also requires the employer to provide the basic information on respirators in Appendix D of this section to employees who wear respirators when not required by this section or by the employer to do so.
29 CFR 1910.134 (k)(5) – “Retraining shall be administered annually, and when the following situations occur: (i) Changes in the workplace or the type of respirator render previous training obsolete; (ii) Inadequacies in the employee’s knowledge or use of the respirator indicate that the employee has not retained the requisite understanding or skill; or (iii) Any other situation arises in which retraining appears necessary to ensure safe respirator use.”
29 CFR 1926.103 – “[Note: The requirements applicable to construction work under this section are identical to those set forth at 29 CFR 1910.134 of this chapter.]”
Asbestos (Construction Industry)
29 CFR 1926.1101 (k)(9)(ii) & (ii) – “The employer shall train each employee who is likely to be exposed in excess of a PEL, and each employee who performs Class I through IV asbestos operations, in accordance with the requirements of this section. Such training shall be conducted at no cost to the employee. The employer shall institute a training program and ensure employee participation in the program. Training Requirements in OSHA Standards 219 Training Requirements (ii) Training shall be provided prior to or at the time of initial assignment and at least annually thereafter.”
Chromium (Construction Industry)
29 CFR 1926.1126 (m)(4)(ii) – “Training shall be provided prior to or at the time of initial assignment to a job involving potential exposure to cadmium and at least annually thereafter.”
AGRICULTURE INDUSTRY
Guarding of Farm Field Equipment, Farmstead Equipment, and Cotton Gins (Agriculture Industry)
29 CFR 1928.57 (a)(6) – “Operating instructions. At the time of initial assignment and at least annually thereafter, the employer shall instruct every employee in the safe operation and servicing of all covered equipment with which he is or will be involved, including at least the following safe operating practices: (i) Keep all guards in place when the machine is in operation; (ii) Permit no riders on farm field equipment other than persons required for instruction or assistance in machine operation; (iii) Stop engine, disconnect the power source, and wait for all machine movement to stop before servicing, adjusting, cleaning, or unclogging the equipment, except where the machine must be running to be properly serviced or maintained, in which case the employer shall instruct employees as to all steps and procedures which are necessary to safely service or maintain the equipment; (iv) Make sure everyone is clear of machinery before starting the engine, engaging power, or operating the machine; (v) Lock out electrical power before performing maintenance or service on farmstead equipment.”
Roll-Over Protective Structures (ROPS) for Tractors Used in Agricultural Operations
29 CFR 1928.51 (d) – “Operating instructions. Every employee who operates an agricultural tractor shall be informed of the operating practices contained in Appendix A of this part and of any other practices dictated by the work environment. Such information shall be provided at the time of initial assignment and at least annually thereafter.”
