What Does this Mean, "Are You OSHA Compliant to do this Training?"
I sent a quote to a customer two weeks ago! It was a quote for “PIT Train-the-Trainer” training, something I have done many times and am very comfortable. Yesterday I got an email from him that was surprising in content, “Looks like we are good, but Corporate EHS wants to know if you are OSHA Compliant to teach this course?”
Most of us know that OSHA does not “Certify, Approve, or label anyone Compliant” so I was surprised at the question, especially from a department with alleged OHS professionals. Basically, I answered probably a little like a college professor. I told him that OSHA does not really give credentials for the kind of training we are doing. I did say that I was an “Authorized OSHA Outreach Instructor” but that was for information purposes.
I ended by saying OHSA issues standards that they expect all employers to follow. The training I would provide would give him the information to be compliant with the applicable OSHA standards, in this case “1910.178 Powered Industrial Truck.” I reminded him that I was not approving him operating his company’s equipment but training him in the tools he needed to do so as an agent of his company. My training would show him how to have an OSHA Compliant PIT Program that exceeded OSHA’s expectations, and that was how he became “OSHA Compliant!”
What would you have said?
Comments (9)
While OSHA doesn't come out and say it directly in 1910.178, they do have PIT trainer/evaluator qualifications found in various standard interpretations. The term "compliant" just means you comply with OSHA's requirement - not necessarily that OSHA is the one saying you are compliant. So technically, you would have to be "compliant" as an instructor, and your training course that you provide would have to be "compliant" by teaching them everything they need to know to properly instruct a PIT operator course.
In a nutshell, OSHA says you have to have "been there, done that" in order to evaluate PIT operators. If you have never operated that class of PIT yourself, then OSHA would say you're not qualified to evaluate others operating that class of PIT. Same concept if you haven't used a particular forklift attachment, then you wouldn't be qualified to evaluate others using it.
Now, with that being said, OSHA doesn't recognize or even touch on "Train-the-Trainer" courses as far as requirements - they just say it's one way to potentially become a qualified trainer and/or evaluator, but is not required. But, it also goes back to the above - if you're not a qualified trainer yourself, then how can you train others to be qualified trainers? For example, if you've never operated a telehandler (class 7 PIT), how would you consider yourself "qualified" to train others on this, and therefore, how would your TTT program be "compliant"?
OSHA does have a standard interpretation out regarding a PIT TTT course (link below), but just simply says what I mentioned above and that it's also not required.
When we teach train-the-trainer courses, we cover 2 things over 2 days (16 hours): day 1 covers instructor methodology and applicable regulations (ANSI B56 series, ANSI Z490.1 standard, NESHTA guidelines, OSHA 1910.178, etc.), day 2 covers them actually performing said training themselves (so for a PIT TTT course, day 2 would involve them conducting a PIT operator course and me evaluating them on it, providing feedback, making necessary corrections, and them demonstrating to me their competency and qualifications as a "trainer" before I give them any type of certification).
To answer your question, I would send them whatever applicable credentials you have to demonstrate you are qualified to (1) train PIT operators yourself, and (2) train other trainers on instructor methodology, how to structure a class, etc.
https://www.osha.gov/laws-regs/standardinterpretations/2000-04-10-0
I am humbled by the expertise of all of you, but especially Drew and John. I would like to think I know a little about OHS but am not sure I am in your leagues. Your safety knowledge is astounding. However, I am a manufacturing guy and my safety management knowledge is tempered with as much experience in Operations and HR as OHS. (Note I did not say EHS - I hate the E and run form that).
As an Ops Manager I want to know the "bottom-line!" Cut to the chase, tell me the bottom-line, and just tell me what I have to do! Let's do it and get the machines running! Up time or in Lean terms add value (eliminate waste) is the name of the game! In HR (where my education is) I think of protecting the resources of the organization, especially our people resource. Worst case is going to court and having to go up on a witness stand and testify to protect said organization. That is the very bottom line to me in decisions like this. I picked someone to do important authorized training. Is my pick based on logic and a good-faith decision that I can I defend, ultimately (or worst case) in a hearing or court. Bottom line is can I defend my position?
Now as a consultant my customer usually does not have time for all that! They just want the job done so they are complaint (OSHA) themselves. In this area I am very confident my experience stacks up to anyone! If the subject is beyond my expertise I refer them to others, I do not do it! This kind of training saves lives!
I also have a Masters in training and vast experience. I was told by a professor once, "An awesome trainer can train anyone to do anything!" While I understand and agree with some of that statement, I do not think I should train someone to do Brain Surgery.
PS I spent a lot of time and money developing my LI Profile and my website. I links to those to anyone that asks for my credentials. Reminds me I have to do my annual review and update on those!
Drew hit the nail on the head.
Essentially, these companies can train themselves, but they need to have a competent person administer the practical/hands on portion and also ensure that the user has retained proper knowledge to operate the SPECIFIC equipment/perform a task in adherence to OSHA regulations.
They also need to be able to provide specific breakdowns of what was covered within the training to ensure proper topics were covered in the event that an inspection were to take place.