OSHA HEALTH AND SAFETY TRAINING REQUIREMENTS

                By Michael McCann, PhD, CIH





   The purpose of this fact sheet is to provide guidance to art

schools and departments, schools, theaters, museums and other

employers in the arts on health and safety training requirements

mandated by the Occupational Safety and Health Administration

(OSHA) for employees. These training requirements are found in

the Occupational Safety and Health Standards for General Industry

(29 CFR 1910) and Construction (29 CFR 1926).  Public employees

in New York State are protected by the New York State Public

Employees Safety and Health Act.  Public employees in others

states with OSHA-approved state plans also have to obey these

OSHA regulations.



OSHA STANDARDS REQUIRING TRAINING



    This data sheet covers OSHA training requirements for:    þ  

AIDS/HIV and Hepatitis B;

þ   Hazardous substances;

þ   Noise;

þ   Welding, cutting and brazing;

þ   Personal protective equipment;

þ   Emergency planning and fire protection;

þ   Electrical and energy hazards; 

þ   Medical services;  and 

þ   Accident prevention signs and tags.

    Besides the training requirements for the above subjects, 

OSHA requires training for other specific hazards such as

asbestos, lead, cadmium, ionizing radiation, etc.  Contact the

specific OSHA standards for training requirements. 



WHEN IS TRAINING REQUIRED?



    Most OSHA standards require training upon the initial

assignment to a job with potential hazards, and whenever exposure

conditions subject to training change.  Some standards also have

requirements for annual training.  The training must be at no

cost to employees and during regular working hours.



WHO DOES THE TRAINING?



    Most standards do not specify who does the training, or the

qualifications of the trainer.  The Bloodborne Pathogens Standard

is an exception to this, requiring a qualified trainer and

forbidding use of videotapes alone. 



WHAT DOES THE TRAINING COVER?



   Most OSHA standards specify what topics have to be covered in

training.  The training should be appropriate in content and

vocabulary to the educational level, literacy, and language of 

the involved employees.  Many recent OSHA standards require that

employers show that employees understand the material covered,

and certify that adequate training has occurred.



AIDS/HIV AND HEPATITIS B 



   Employees who face a significant risk of occupational exposure

to blood or body fluids must receive at least annual training

under OSHA's Bloodborne Pathogens Standard [29 CFR 1910.1030].

The trainer must know the subject matter as it applies to the

specific workplace addressed by the training.  Training

requirements include: 

þ   An explanation of the standard and the employer's exposure

control plan; 

þ   Who is at risk, symptoms, method of transmission, and  how

to recognize activities that may involve exposure   to blood and

body fluids;

þ   Use and limitations of methods to reduce or prevent   

exposure (universal Precautions); 

þ   The types, selection, proper use, location, removal,

handling, decontamination and disposal of personal protective

equipment;

þ   Information on the Hepatitis B vaccine, including

effectiveness, safety, method of administration, and benefits of

free  vaccination;

þ   What to do and who to contact in an emergency involving

blood or other potentially infectious materials;

þ   Procedures to follow in an exposure incident, including

reporting method and  medical follow-up; 

þ   The employer's post-exposure evaluation and follow-up after

an exposure incident; 

þ   Explanation of signs, labels and/or color coding; and 

þ   An opportunity for question and answer period with the

trainer.



HAZARDOUS SUBSTANCES



TOXIC SUBSTANCES

    OSHA's Hazard Communication Standard requires that employers

provide training to all employees exposed to hazardous chemicals

[29 CFR 1910.1200].  This training must be done at the time of

initial assignment and whenever a new hazard is introduced into

the area.  Training must include information on: 

þ   The requirements of the HazCom standard;

þ   Operations  where hazardous chemicals are present; 

þ   The location and availability, of the written HazCom

Program,  lists of hazardous chemicals, and Material Safety Data

Sheets (MSDSs); 

þ   Ways to detect the presence or release of hazardous

chemicals in the workplace; 

þ   Physical and chemical hazards of the chemicals present;  þ  

Precautions, including work practices, emergency procedures and

personal protective equipment; and 

þ   Details on the  HazCom Program, labeling system, and how to

interpret MSDSs; New York State's Right To Know Law, enforced by

the NYS Attorney General's Office, has more stringent training

requirements for public employees routinely exposed to toxic

substances.  This law requires that the training be done before

the introduction of new hazardous chemicals, if exposure

conditions change, and at least annually. Training requirements

for toxic substances include: 

þ   Their location;

þ   Their properties;

þ   Their names, including generic or chemical names, trade

names and other commonly used names; 

þ   Their acute and chronic effects;

þ   The symptoms of exposure at hazardous levels;

þ   The potential for flammability, explosivity, and reactivity; 

þ   Emergency procedures;

þ   Proper conditions for safe use and exposure; and

þ   Cleanup and spill procedures.



LABORATORIES

   OSHA's Occupational Exposure to Hazardous Chemicals in

Laboratories Standard [29 CFR 1910.1450] applies to all

laboratories that use hazardous chemicals on a laboratory scale.

Employees must be informed and trained in the hazards of

chemicals present in their work area at the time of initial

assignment, prior to assignments involving new exposures, and be

given refresher training at a frequency to be determined by the

employer.  Laboratories do not have to comply with OSHA's HazCom

Standard, but do have to conduct NYS Right To Know training.   

Requirements for information and training include:  

þ   The contents of this standard and its appendices;

þ   The location, availability and applicable details of the

employer's written Chemical Hygiene Plan; 

þ   Permissible Exposure Limits of chemicals used;

þ   Signs and symptoms of exposure;

þ   Location and availability of known reference materials 

(including Material Safety Data Sheets); 

þ   Methods and observations to detect the presence or release

of a hazardous chemical;  

þ   Physical and chemical hazards of chemicals in the work area;

and 

þ   Precautions employees can take to protect themselves.



ETHYLENE OXIDE

  OSHA's Ethylene Oxide Standard (29 CFR 1910.1047) requires that

employees who are potentially exposed to ethylene oxide (EtO) at

or above the action limit or above the excursion limit be trained

at the time of initial assignment and at least annually. 

Training and information requirements include: 

þ   Information on the standard and its appendices, and its

location and availability; 

þ   Operations in the work area where EtO is present;

þ   Information on medical surveillance requirements;

þ   Methods and observations that may be used to detect the

presence of EtO in the work area; 

þ   The physical and chemical hazards of EtO;

þ   Precautions, including work practices, emergency procedures,

and personal protective equipment; and 

þ   Details of  the Hazard Communication Program.



CONFINED SPACES

   OSHA's Permit-Required Confined Spaces Standard [29 CFR

1910.146] requires that employees who enter, attend, supervise or

monitor permit-required confined space entry must be trained 1)

before first assignment, 2) before a change in assigned duties,

3) if there is a change in the hazard for which the employees

have not been trained, 4) if the employer's required procedures

are not being followed, or 5) if there are inadequacies in an

employee's knowledge or use of these procedures.  The training

must ensure an employee's understanding, knowledge, and skills

needed.  Training must be certified by the employer.  Training

requirements include:

þ   Possible hazards, including information on the mode, signs

or symptoms, and consequences; 

þ   Proper use of required equipment;

þ   Knowledge of procedures required by particular assignments;

and 

þ   Employees with rescue duties must also practice permit space

rescues at least once every 12 months, and must be trained in

first aid and CPR.



SPILLS AND LEAKS    

  OSHA's Hazardous Waste Operations and Emergency Response

Standard [29 CFR 1910.120] covers emergency response to spills

and leaks.  Section Q of this standard has extensive training

requirements for employees who participate, or are expected to

participate, in emergency responses to spills and leaks. This

training must take place before an employee can take part in

emergency responses.  Annual refresher training or  annual

demonstration of competency is required. 

  Different levels of training and/or competency are required for

first responders at the awareness level, first responders at the

operations level, hazardous materials technicians, hazardous

materials specialists, and on-scene incident commanders. 

Trainers must have completed training courses in the subjects or

have other acceptable qualifications.  Training or competency

determination must be certified by the employer. 



NOISE 

   OSHA's Occupational Noise Exposure Standard (29 CFR 1910.95)

requires training of all employees who are exposed to noise

levels at or above an 8-hour time-weighted average of 85

decibels. This training must be repeated annually for each

employee in the hearing conservation program.  The training must

include: 

þ   The effects of noise on hearing;

þ   The purpose of hearing protectors, advantages,

disadvantages, and attenuation of various types; 

þ   Instructions on selection, fitting, use, and care of hearing

protectors; and 

þ   The purpose of audiometric testing and an explanation of

test procedures.



WELDING, CUTTING AND BRAZING

  OSHA's Welding, Cutting and Brazing Standards (29 CFR

1910.251-1910.255) have several training requirements.  These

are:

þ   Fire watchers must be trained in the use of fire

extinguishing equipment. 

þ   Management must insist that cutters or welders and their

supervisors are suitable trained in the safe operation of

equipment and safe use of processes.

þ   Workmen in charge of oxygen or fuel-gas supply equipment,

including generators and distribution piping systems, must be

instructed before being left in charge.  Rules and instructions

must be readily available.

þ   Operators of arc welding equipment must be properly

instructed and qualified to operate such equipment.  Operators

and maintainers of arc welding equipment must be acquainted with

the requirements of 1910.252(a), (b), and (c), and 1910.254(d).  

þ   Operators and maintainers of gas-shielded arc welding

equipment must be acquainted with the above requirements, and

also those of Recommended Safe Practices for Gas-Shielded Arc

Welding, A6.1-1966, American Welding Society.

þ   Operators of resistance welding equipment must be properly

instructed and judged competent to operate such equipment. 

PERSONAL PROTECTIVE EQUIPMENT



RESPIRATORY PROTECTION

  OSHA's Respiratory Protection Standard [29 CFR 1910.134]

requires training  for employees who are required to wear

respirators.  Instruction must be done by competent persons. 

Training must include: 

þ   The proper use and limitations of respirators;

þ   The proper selection, use and maintenance of respirators;  

þ   Instructions and hands-on experience in handling, proper

fitting, testing of seal, adjusting, wearing in  normal

atmosphere for a long familiarity period, and wearing in a test

atmosphere; and 

þ   The written procedures covering the safe use of respirators

in dangerous atmospheres;  In addition, the individual

supervising the required respirator protection program must be

qualified and be instructed in the proper selection, use, care,

cleaning and maintenance of respirators. Supervisors must also be

trained in the proper selection, use and maintenance of

respirators.



OTHER PERSONAL PROTECTIVE EQUIPMENT

  OSHA's updated Personal Protective Equipment Standard requires

that employees required to wear personal protective equipment

(PPE) be trained in its use (excluding respirators) [29 CFR

1910.132].  The standard requires that employees must demonstrate

an understanding of the training and an ability to use PPE

properly before being allowed to perform work requiring  PPE.

Employers must retrain employees who do not have the

understanding and skills required,  or when workplace changes or

PPE changes make previous training obsolete.  The employer has to

certify the training in writing.   Employees must be trained to

know at least the following: 

þ   When PPE is necessary;

þ   What PPE is necessary;

þ   The proper use of PPE;

þ   The limitations of PPE; and

þ   The proper care, maintenance, useful life, and disposal of

PPE.



EMERGENCY PLANS AND FIRE PROTECTION



EMERGENCY ACTION AND FIRE PREVENTION PLANS 

  OSHA's  Employee Emergency Plans and Fire Prevention Plans

Standard [29 CFR 1910.38] requires training for all persons

assigned to assist in the emergency evacuation of employees. This

training must take place when any emergency plan is developed or

changed, or when an employee's responsibilities under the plan

change. The employer must review with each employee applicable

parts of the emergency plan, and the written plan must be

available for employee review. 

    This OSHA standard also requires training of all employees

about the fire hazards of the materials and processes associated

with their work tasks.  In addition, the employer must review

with each employee  the parts of the fire prevention plan

affecting the employee. The written plan must be available for

employee review. 

    For employers with 10 or fewer employees, these plans need

not be written.



FIRE BRIGADES

  OSHA  Fire Brigades Standard [29 CFR 1910.156] requires

training of all fire brigade members before they can perform fire

brigade emergency activities. Retraining must be frequent enough

to ensure each fire brigade member can perform assigned duties

satisfactorily and safely (at least quarterly for interior

structural fire fighting, otherwise at least annually). The

training must be suitable to the assigned duties and functions.

Information, including written procedures, must also be provided

on special hazards such as storage and use of flammable liquids

and gases, toxic chemicals, etc. to which fire brigade members

may be exposed during fire and other emergencies. Fire brigade

leaders and instructors must be provided with more comprehensive

training. The quality of the training and education program must

be similar to those conducted by fire training schools. 



PORTABLE AND FIXED FIRE EXTINGUISHERS

  OSHA's  Portable Fire Extinguishers Standard [29 CFR 1910.157]

requires training,  upon initial employment and annually

thereafter, of all employees expected or allowed to use fire

extinguishers.  Training requirements for employees allowed to

use fire extinguishers include familiarization with general

principles of fire extinguisher use and with hazards associated

with incipient stage fire fighting. Employees designated to use

fire fighting equipment must receive training, including hand-on

practice, in the use of appropriate fire fighting equipment.    

OSHA's Fixed Extinguishing Systems Standard   [29 CFR 

1910.160] requires training of all employees designated to

inspect, maintain, operate, or repair fixed extinguishing systems

installed to meet an OSHA standard, excluding automatic sprinkler

systems.  The training must be reviewed annually for up-dating. 

FIRE DETECTION SYSTEMS

   OSHA's Fire Detection Systems Standard [29 CFR 1910.164]

requires that all employees who service, maintain, and test fire

detection systems must be trained and knowledgeable in the

operations and functions of the system.



ELECTRICAL AND ENERGY SAFETY



ELECTRICAL SAFETY PRACTICES

  OSHA's Electrical Safety-Related Work Practices  Standard [29

CFR 1910.332] requires training of employees facing a risk of

electrical shock that is not reduced to a safe level by

precautions in 1910.303-1910.308.  This includes blue collar

supervisors, electrical and electronic engineers and technicians,

electricians, industrial machine operators, material handling

equipment operators, mechanics and repairers, painters, riggers

and roustabouts, stationary engineers and welders.  

   Such employees must be trained in and familiar with the

safety-related work practices required by 1910.331 - 1910.335

that pertain to their job assignments.  Unqualified persons at

risk (those not permitted to work on or near exposed energized

parts) must also be trained in other safety practices necessary

for their safety.  

  Qualified persons must at a minimum be trained in: 

þ   The skills and techniques needed to distinguish live parts

from other electrical equipment parts;  

þ   The skills and techniques needed to determine the voltage of

exposed live parts; and 

þ   The clearance distances specified in 1910.333(c), and

corresponding voltages.



ENERGY CONTROL (LOCKOUT/TAGOUT)

   OSHA's Control of Hazardous Energy (Lockout /Tagout) Standard

[29 CFR 1910.147] requires  training of all employees where

servicing and maintaining machinery and equipment could cause

injury to the employee through the release of stored energy. 

Retraining  must be done: 1) when there is a change in

assignments; 2) a change in machines, equipment or processes that

present a new hazard; 3) a change in energy control procedures;

or 4) if periodic inspections show or the employer believes an

employee has inadequate knowledge or use of energy control

procedures.  

  Employees authorized to service or maintain machinery and

equipment must be trained in: 

þ   The recognition of applicable hazardous energy sources;    þ 

 The type and magnitude of the energy available; 

þ   Methods for energy isolation and control; and

þ   The purpose and use of  energy control procedures.  Other

affected employees in the work area must be instructed in energy

control procedures, and in the prohibition of restarting or

reenergizing machinery that has been locked out or tagged out.

For tagout systems, authorized and affected employees must be

trained in the limitations of tags.  The employer must ensure

that the purpose and function of the energy control program is

understood, and that employees have obtained the needed knowledge

and skills. The employer must also certify that training has been

accomplished and is up to date. 



MISCELLANEOUS



MEDICAL SERVICES AND FIRST AID

   OSHA's standard on Medical Services and First Aid [29 CFR

1910.151] requires that one or more persons  receive adequate

first aid training to render first aid, if there is no infirmary,

clinic or hospital in near proximity to the workplace which is

used for the treatment of all injured employees.



ACCIDENT PREVENTION SIGNS AND TAGS

   OSHA's standard on specifications for accident prevention

signs and tags [29 CFR 1910.145] requires instruction of all

employees in the following:

þ   The meaning of danger signs;

þ   The meaning of warning signs;

þ   The meaning of warning instruction signs; and

þ   The meaning of accident prevention tags. 





This data sheet was adapted from a data sheet prepared for the

New York State Public Employees Federation.  





(c) Copyright Center for Safety in the Arts 1995