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.