This is not to say that having proper documentation isn‰??t useful or good. It‰??s great as an admin control to make sure people get their training, and documents settle a lot of compliance arguments. Besides, DOT and EPA require training docs for specific trainings too, like AHERA qualifications. I don‰??t recall any general requirement to document everything in EPA, though‰??is there a specific example you had in mind?

Regards, Dan

Sent from my iPad

> On Oct 23, 2020, at 17:06, Stuart, Ralph wrote:
>
> •ÈÀ
>>
>> there was a court decision (OSHA v. Westvaco?) that held that OSHA cannot require any documentation not specifically asked for by a reg.
>
> So, while DOT and EPA regulations require safety training documentation (for specific hazmat related jobs), OSHA can't for general safety training? I've been working in compliance for 35 years and never picked up on that subtle point. I suppose OSHA's proposed regulations have a high paperwork reduction standard to cross...
>
> Thanks for the explanation.
>
> - Ralph
>
>
> Ralph Stuart, CIH, CCHO
> Environmental Safety Manager
> Keene State College
> 603 358-2859
>
> ralph.stuart**At_Symbol_Here**keene.edu
>
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