OSHA requires that emergency training shall be “hands on,” annual, at hire, in a classroom “where questions can be asked and answered,” by a “qualified” trainer (by dint of experience or training). If any of you want to see the brief detailing the citations on this, email me.
Employers always ask me, “When does it mean we train ‘at hire?’ Does that mean day one? Can we wait 30 or 90 days? Or for the next annual training?”
OSHA’s just-issued answer: “A worker’s first day at work shouldn’t be his last day on earth.” This from OSHA’s Director, Assistant Secretary of Labor David Michaels.
His earnest statement concerns Bacardi USA, which hired a temp who was killed by a machine on his first day. The fine ordered is $192,000. See the attached PDF.
Insight for you: Many employers are comfortable waiting 30-90 days to train new employees or contractors who work on premises for days, weeks or months. OSHA had not given any guidance or enforcement action on timing…until now.
This case is about a manufacturer. Nevertheless, it will be used against you if you are a professional service, campus, medical facility, etc.
“Let’s be careful out there.”