

EXECUTIVE SUMMARY

On June 7, 2011, the Federal Advisory Council on Occupational Safety and
Health (FACOSH) tasked its Training Subcommittee with developing
occupational safety and health (OSH) training guidelines that would
achieve consistency at all staff levels across the Federal Government
for training requirements contained in 29 CFR Part 1960. The guidelines
are designed to provide training that is tailored to the broad set of
responsibilities and duties that are applicable for a given staff level.
 Agencies can utilize the guidance to identify and address deficiencies
and gaps in their OSH training programs. The following recommendations
for FACOSH, as well as the attached training guidelines (Appendix A) and
generic training Standard Operating Procedure (Appendix B) are the
product of the subcommittee’s effort.  

ISSUE

To achieve consistent safety and health training across the Federal
Government, there is a need for uniform OSH training guidelines at all
staff levels.

RECOMMENDATIONS

1A)	The Secretary should direct OSHA to develop and issue Occupational
Safety and Health (OSH) training guidelines for Federal agencies. The
guidelines should:

Establish a fundamental baseline of OSH training elements that Federal
agencies should use when developing and providing training for Federal
employees.  

Address the frequency and duration of required OSH training.

Identify a method or means of assuring that Federal agencies provide
employees with required OSH training and that the employees understand
the OSH training that they receive.

Give agencies latitude to implement the most effective and efficient
methods of delivering required OSH training.

Require agency heads to develop and implement a program for evaluating
the effectiveness of their OSH training and training delivery methods.  

Include a sample Standard Operating Procedure to aid agencies with the
implementation of the OSH training guidelines.

 

1B)	The Secretary should direct OSHA to revise 29 CFR Part 1960: 1) for
agencies to provide employees with annual OSH training that covers new
or emerging hazards as well as issues of importance to a given agency or
job task/function and 2) to  make the failure to provide annual OSH
training citable by OSHA. 

1C)	The Secretary should direct OSHA to send a memorandum to the
Designated Agency Safety and Health Officials (DASHOs) announcing the
issuance of OSH training guidelines for Federal agencies.  The memo
should encourage DASHOs to utilize safety and health experts from
whatever source available when developing OSH training, including but
not limited to other agencies, professional groups, consultants,
universities, labor organizations, and safety and health committees.

1D)	The Secretary should correspond with agency heads emphasizing their
responsibility to provide employees with OSH training consistent with
the revised standards of 29 CFR 1960.

2A)	The Secretary should send a memorandum to the Director of the Office
of Personnel Management (OPM) requesting that OPM training orientation,
training resources, and the OPM Federal Training Policy Handbook include
OSH information and materials for supervisors, managers, and executives
that will enable them to implement the OSH programs of their agencies. 
Such orientation should include coverage of section 19 of the Act,
Executive Order 12196, and the requirements of 29 CFR 1960.  

2B)	The Secretary should request that OPM distribute OSHA training
requirements by: 1) Posting them to the OPM website, and 2)
Communicating them to agency heads, human resource departments, and
Employee Assistance programs.

2C)	The Secretary should request that OPM update the section of the OPM
Federal Training Policy Handbook titled, Supervisory, Managerial, and
Executive Development Federally Mandated Training, to include OSH
training time-frames for all employees and for supervisors.

3A)	The Secretary should direct OSHA to monitor agencies’ OSH training
programs through inspections and evaluations.  During monitoring
activities, OSHA should verify that employee training records are
retrievable and clearly identifiable as meeting the requirements of 29
CFR 1960.

3B)	The Secretary should direct OSHA to include a requirement in the
annual report for agency heads to provide written summaries of their OSH
training and self-evaluations, including: 1) evidence verifying that OSH
training was developed in accordance with the requirements set forth in
29 CFR 1960 and EO 12196; 2) a list of the training conducted,  3)
information pertaining to the matrix the agency used to evaluate the
effectiveness of its OSH training and training delivery methods; and 4)
documentation of the funding allocated to OSH .

3C)	The Secretary should direct OSHA to widely publicize the new
reporting requirements for training to the DASHOs and safety and health
managers, prior to including it in the annual report request.  

APPENDIX C

The following list contains the names of FACOSH members, Technical
Experts, and OSHA staff who actively participated on the Training
Subcommittee during its analysis of safety and health training
requirements for all staff levels of Federal agencies.

FACOSH Members

Dennis Bushta, Deputy Director, Office of Administration, Environmental
Protection Agency

Deborah Kleinberg, Counsel, Seafarers International Union, AGLIWD

William Kojola, MS, Industrial Hygienist, Safety and Health Department,
AFL-CIO

Milagro “Milly” Rodriguez, Occupational Health and Safety
Specialist, AFGE

Technical Experts

Craig Brown, Senior Industrial Hygienist, U.S. Department of Veteran
Affairs

Henry Cleveland, Program Analyst, U.S. Department of Veteran Affairs

Edward Collier, U.S. Environmental Protection Agency

Cathie Cronin, Director, Office of Training and Educational Development,
Occupational Safety and Health Administration, U.S. Department of Labor

Chesha Gartmon, Program Manager, U.S. Department of the Treasury

Brian Marcyjanik, General Safety Program Manager, U.S. Department of
Veteran Affairs

Brenda Miller, Senior Safety Advisor, U.S. Department of the Army

Lynn M. O'Brien, CP-12 Program Administrator, U.S. Department of the
Army

Daniel Pubal, Safety and Occupational Health Manager, Federal Aviation
Administration

David Smith, U.S. Department of Energy

Howard Wilson, Deputy Director, Safety, Health and Environmental
Management Division, U.S. Environmental Protection Agency

David Wynn, Environmental Protection Agency

OSHA Staff

Francis Yebesi, Director, Office of Federal Agency Programs,
Occupational Safety and Health Administration, U.S. Department of Labor	

Mikki Holmes, Supervisor, Office of Federal Agency Programs,
Occupational Safety and Health Administration, U.S. Department of Labor

Mandi Dermer, Program Analyst, Office of Federal Agency Programs,
Occupational Safety and Health Administration, U.S. Department of Labor

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Recommendations for Consideration by the Secretary of Labor on Uniform
Occupational Safety and Heath Training Guidelines for the Federal
Government

Prepared by the  

Federal Advisory Council on Occupational Safety and Health

(FACOSH)

 

