Dear Mr. Peculski:
Thank you for your training inquiry. In general, OSHA standards
are the baseline minimum safety requirements, and we applaud you for your goal of exceeding OSHA training requirements. Although
we prefer the use of specifically tailored programs as a best practice, we must answer from a compliance standpoint. The question
of using distributor materials vs. your own programs centers on what complies with the particular OSHA standard. If the training
program complies with OSHA requirements and protects employees, the training is acceptable from an enforcement standpoint.
Note that each standard has its own training language. The confined space standard 1910.146(g)(1) states "The employer shall
provide training so that all employees whose work is regulated by this section acquire the understanding, knowledge, and skills necessary
for the safe performance of the duties assigned under this section." Permit confined space entry can pose life threatening hazards.
Can an employer meet the requirements using a generic program? It may be possible, but it's not likely and certainly not recommended.
Without a knowledgeable trainer and workplace specific training the employer is putting employees and the company at risk.
There are many generic hazard communication training programs. These are acceptable but must be supplemented by workplace specific
information. Note that 1910.1200(h)(3) often incorporates workplace specific language "such as monitoring conducted by the employer,"
"including specific procedures the employer has implemented to protect employees from exposure to chemicals," and "details of the
hazard communication program developed by the employer."
Part of our job at OSHA is to influence employers
to be proactive in safety. They need to look beyond compliance at the bigger picture of product quality, protection of assets,
worker's compensation costs, hidden costs, their reputation, and other factors. A good safety program including good training
has given many employers a competitive edge as well as a marketing tool. Basic compliance is only the starting point.
Charles J. Shields
OSHA Training Institute Director
The response below is based upon a question posed to OSHA from our organization regarding generic videos
and training kits used by non-certified / experienced instructors to meet minimum compliance. We expressed concerns about generic
training programs that do not address customer's specific hazards that they may face.