Ask the expert: What does OSHA mean by annual training?

By: June 25th, 2010 Email This Post Print This Post

Q: What does OSHA mean by annual training—every 12 months or within each calendar year?

A: While the language varies across standards—sometimes saying every 12 months, other times described as at least annually—annual training, as far a s OSHA is concerned always means “at least once every 12 months,” according to a January 24, 2007 OSHA interpretation letter, “Acceptable time lapse for ‘annual’ training.For example, if you usually train employees in December, but for some reason conduct training mid-year instead, and then go back to December training the next year (e.g. December 2008, June 2009, December 2010) you would have training for three consecutive calendar years but it would not meet the standard of the requirement for at least every 12 months.

This is an actual example from a reader who received such a citation.


By Judy Ruggeri on June 26th, 2010 at 3:04 pm

What are the requirements for training? Can a DDS train his staff at a staff meeting? Can a member of the staff train the employees if they are knowledgeable in the subject being covered?

Regarding Judy Ruggeri’s question: Absolutely! A DDS or any member of their staff can train the office. They must be knowledgeable enough to answer any questions posed to them as a direct result of the training, knowledgeable in the content of the training, and familiar with any updates. This is very important because you never want a current or ex-employee stating to OSHA their training was subpar or lacked the necessary elements.

If you do not want to be culpable for anything missed or misrepresented during the training, there are other ways to meet this mandatory requirement 1) purchasing an in-office training system, preferably one with a toll-free number should you have questions 2) attending your local dental society or ADA annual training session for your state or 3) inviting someone who specializes in OSHA training to your office. Many of these options also include continuing education credits, good toward your license renewal.

Whichever method you choose, just remember to include everyone in the training. Though, depending on their duties some office personnel might be excluded, by including them everyone has a say about, and contributes to, the culture of safety in the office!


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