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|Title: 10/24/2005 - Training programs for the Control of Hazardous Energy (LOTO) and for the Hazard Communication standard are not satisfied solely by merely providing employees written documentation.
|Record Type: Interpretation
|Standard Number: 1910.147; 1910.147(c)(7)(i); 1910.1200; 1910.1200(h)
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Thank you for your September 25, 2003 letter to the Occupational Safety and Health Administration (OSHA) concerning training requirements under OSHA's Control of Hazardous Energy (Lockout/Tagout) standard, 29 CFR 1910.147, and OSHA's Hazard Communication standard (HCS), 29 CFR 1910.1200. This letter constitutes OSHA's interpretation only of the requirements discussed and may not be applicable to any question not delineated within your original correspondence. We apologize for the delay in our response.
Your paraphrased scenarios, questions, and our responses are provided below.
Scenario: Several years ago, we had a rather comprehensive training session on lockout/tagout. Since that time, a significant number of employees have been reassigned and presently work with different machines. The employees exposed to new machinery have never been trained on how to properly lock out that machinery. We receive a generalized training session once a year during our 1-hour, routine monthly meeting. However, this meeting is not specific to lockout/tagout and includes discussion on Behavior Based Safety, tracking our safety record against targeted safety numbers, and various other topics.In addition, I have assisted in developing the lockout/tagout procedures for machinery in a new department. Copies of the procedures were distributed to the maintenance employees. However, there has never been any discussion of the procedures. The company has never insured that these employees had a total understanding of these procedures.
Question 1: Is it acceptable to merely distribute copies of lockout/tagout procedures and consider that to be lockout/tagout training? If not, what are the general criteria for lockout/tagout training?
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Question 2: Is it acceptable merely to distribute copies of MSDSs and consider that to be training? If not, what are the criteria for training?
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Appendix A of the Compliance Directive for Hazard Communication, CPL 2-2.38D explicitly provides that "[t]he training provisions of the HCS are not satisfied solely by giving employees the [material safety] data sheets to read. An employer's training program is to be a forum for explaining to employees, not only the hazards of the chemicals in their work area, but also how to use the information generated in the hazard communication program. This can be accomplished in many ways (audio visual, classroom instruction, interactive video), and should include an opportunity for employees to ask questions to ensure that they understand the information presented to them."
The HCS directive, which is available on OSHA's website at www.osha.gov, also provides additional information concerning an employer's obligation to provide employee training under the HCS. Other useful information pertaining to the Hazard Communication standard can be found at: http://www.osha.gov/SLTC/hazardcommunications/solutions.html.
Richard E. Fairfax, Director
Directorate of Enforcement Programs
The official, public domain, OSHA version of this document is available at http://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=INTERPRETATIONS&p_id=25160&p_text_version=FALSE