Training Certification and Documentation — OSHA Letters of Interpretation

In a letter on contractor training, OSHA spelled out what PSM training records must include: the identity of the employee, the date of training, and the means used to verify that the employee understood the training. The employer responsible for the training must make sure adequate means were used to verify understanding and must keep the records.

Asked whether operators could lose their jobs for failing a test after refresher training, OSHA said employers need "appropriate methods, such as written tests, oral examinations, simulation exercises, etc., to ensure that employees understand the training they have received," and that "only those who have demonstrated the ability to do their jobs safely" should work on hazardous processes. OSHA declined to weigh in on employment decisions.

In a memo on a utility's plan to let employees test out of annual refresher classes, OSHA called challenge testing "an excellent tool" for confirming knowledge but "not a substitute for skills training." Where a standard requires both knowledge and work-practice refreshers, a challenge test can substitute only for the knowledge part, and an oral test must be certified by the test provider. OSHA recommended a one-year pilot with employee representatives involved.