FOREWARD

The Federal Advisory Council on Occupational Safety and Health (FACOSH)
has determined there is a lack of consistency across the federal
agencies for safety and health training at all staff levels. In response
to this finding, FACOSH approved a recommendation June 7, 2011 that the
Secretary of Labor (the Secretary) convene a cross-cutting government
task force, chaired by OSHA and in consultation with and assistance from
NIOSH, to focus on developing safety and health training guidelines that
would achieve consistency across the federal government for training
requirements contained in 29 CFR Part 1960 at all staff levels. The
Secretary approved this recommendation and, subsequently, under the
direction of the Assistant Secretary of Labor for Occupational Safety
and Health, a government task force was convened to develop the training
guidelines and recommendations. The following training guidelines,
generic training SOP, and specific recommendations for FACOSH are the
product of that task force’s effort.  



Introduction

The following training guidelines apply to the training requirements
found in the Occupational Safety and Health Administration’s
(OSHA’s) Federal Employee Occupational Safety and Health (FEOSH)
standard at 29 CFR Part 1960.  This guideline is intended to define
FEOSH training requirements, establish a baseline as to training
content, and provide guidance as to common elements.  It is intended
that the impact of this effort will be the establishment of a
consistent, standardized safety and health training of federal employees
across the executive branch.

Presently, there is wide variation in the manner and detail of FEOSH
training across the Executive Branch.  This variation may result in
inadequate training for some employees and/or training on the wrong
topics or issues for other employees.  In addition, the lack of
standardization results in an economic impact where inadequate training
has to be repeated or supplemented. 

The guidelines will provide federal agencies with a list of the various
training provisions contained in the OSHA FEOSH standard and guidance on
content, frequency/duration, documentation/assurance, trainer
qualifications, and training methods.

I. Scope of Training

The OSHA FEOSH standard establishes the scope of training needs for six
(6) different employee categories or groups.  Specifically, the standard
addresses safety and health training for: 

Management officials, 1960.54, 

Supervisory employees, 1960.55, 

Safety and health specialists, 1960.56, 

Safety and health inspectors, 1960.57, 

Collateral duty employees & safety and health committee members,
1960.58,  

Employees & employee representatives, 1960.59.

II. Content of Training

The FEOSH training requirements establish some specific training
elements, which are common to each of the six employee categories or
groups, and some training elements, which are unique to a specific
employee category or group.  In addition, while some of the training
elements are specifications of a particular topic; other elements use
performance language to describe the type or extent of training desired.
   

Common Elements

Each of the six major groups or categories of employees addressed in 29
CFR 1960 are required to be trained on four (4) common elements. 
Accordingly, FEOSH training for all employees must include the following
four items:

Section 19 of the Occupational Safety and Health Act of 1970 (OSH Act); 

Presidential Executive Order (E.O.) 12196; 

29 CFR Part 1960, (OSHA FEOSH Standard);  

The specific Agency Safety & Health program.  

In developing training for these four common categories, the object
should be that employees gain an understanding of the general principles
or concepts presented in these documents.  The point of the training
should be to provide employees with a common understanding of the
framework, which supports their safety and health program (items 1-3,
above), and then train them on the general aspects of their agency’s
safety and health program.

Unique Specifications 

In addition to training, which is common to all employee groups
referenced in the standard, some training is unique to specific employee
categories listed in the FEOSH standard.  For example, supervisory
employees are to have training on “motivation of subordinates,”
safety and health specialists are to have training on “analysis of
accident, injury and illness data,” and safety and health inspectors
are to have training on “preparation of reports and findings.”  In
most of these instances, such training is mandated by the Office of
Personnel Management (OPM) as part of the Position Classification
Standards for those particular positions.

As an example, the OPM Job Family Position Classification Standard for
Safety and Health Inspectors, Group 1800, and for Safety and
Occupational Health Manager series, Group 0018, establishes that the
“knowledge required for the position,” must include the ability to,
“prepare reports and technical information.”  Therefore, the only
supplemental training that would be imposed by OSHA’s FEOSH standard
for employees employed as safety and health inspectors would be
agency-specific training on the use of the agency’s unique reporting
system and/or training on the agency’s procedures for filing and
managing such reports.  Similarly, OPM’s General Schedule Supervisory
Guide for determining the managerial and/or supervisory responsibilities
of a federal position states under “Nature of Contacts,” that
supervisors must have skills in “organizational relationships,
authority and/or influence” of subordinates and under “Purpose of
Contacts” it states supervisors must be able to “influence,
motivate, or persuade persons or groups to accept opinions or take
actions.”  Accordingly, the OSHA FEOSH requirement that supervisory
employees are to have training on “motivation of subordinates” is
met in that personnel are to have this motivational skill and ability in
order to initially qualify for a supervisory position under OPM
requirements.

 

The OSHA FEOSH standard does describe some training elements using
performance language, which is intended to describe the type or extent
of training desired.  For example, under the standard section on
“employees and employee representatives;” (1960.59), the standard
requires training “appropriate to the work performed.”  Here OSHA
has used performance language rather than specifications to direct
agencies to provide what is termed today as “job specific training.”
 The intent is to have agencies train to unique conditions found in a
particular position or at a particular worksite.

Appendix A to this guideline provides a table with required training
listed by each of the six (6) major employee categories.

Baseline of Training Content  

To establish a baseline of consistent safety and health training content
for FEOSH training across the federal government,  it is appropriate to
begin with the four “common” elements, which are applicable to each
of the employee groups or categories.  Next, this guideline will
consider for inclusion in this baseline, those elements which are found
in at least two or more of the employee groups described by the
standard.  Where similar training requirements are found in two or more
employee groups and where that training is not a technical specification
directly related to a specific position, this guideline considers it for
inclusion in the baseline training items.  

Using this approach to compile a baseline listing of the training that
the OSHA standard requires for federal employees, nine (9) distinct
subject areas can be identified.  Those areas are: 

 Baseline Elements for FEOSH Training

Section 19 of Public Law 91-596 (the OSH Act);  

Presidential Executive Order 12196, (E.O. 12196); 

29 CFR 1960, Elements for Federal Employee Occupational Safety and
Health Programs and roles and responsibilities; 

General awareness/orientation;

Individual agency’s safety & health (S&H) program; 

How to identify applicable S&H standards; 

Procedures for reporting, evaluating & abating hazards; 

Procedures for reporting & investigating allegations of reprisal; 

Evaluation and abatement of hazards.  

This list comprises the baseline of training topics/subjects, which each
federal agency should use in training federal employees.  Each agency
should use this baseline of training elements in developing and
providing fundamental safety and health training for federal employees. 
Ensuring that the initial safety and health training covers these
fundamental baseline elements leave only a few subject areas unique to
specific employee categories to be addressed.  Accordingly, this
‘baseline’ ensures that consistency in fundamental safety and health
training is established across the Executive Branch.  

Appendix B to this guideline provides a table identifying those training
elements which OSHA would issue as guidance on FEOSH training content. 

This approach does not address some training which is unique to certain
job categories, however, that training must be addressed by individual
agencies based on specified job assignments and duties.  For example,
the training of supervisory employees on “supervisory
responsibilities” and on “motivation of subordinates,” must build
on the OPM Position Classification Standards for those positions and
incorporate agency-specific policy and procedures.  Similarly, employees
in the category of safety and health specialists are to have training on
“analysis of accident, injury and illness data” and that training
must be agency-specific incorporating agency policy, systems and
procedures.  Lastly, the general performance language used to describe
training for employees and employee representatives also must be a
decision unique to individual agencies and to the assignment and duties
of the employees.

Appendix C to this guideline provides a table with the unique or special
training requirements listed by each of the six (6) major employee
categories.

III. Frequency & Duration of Training

OSHA’s FEOSH standard refers to the required training as an
“orientation” and it makes no specific reference to repeating the
training on a periodic basis.  Strictly defined, this training would be
a one-time introduction or general guide about this activity.  While
there is no reference in the OSHA FEOSH standard as to the frequency or
duration of required training or to the need for repeat or follow-up
instruction, there may be some latitude in one of the six job categories
addressed under the standard.  In the section addressing the training of
“safety and health specialist” at 1960.56(b) for example, OSHA
states that, “Each agency shall implement career development programs
for their occupational safety and health specialists to enable the staff
to meet present and future program needs of the agency.”  In addition,
this section addresses training as “courses, laboratory experiences,
field study, and other formal learning experiences.”  This implies
that FEOSH training should include laboratory or “hands-on”
training, peer teaching and interactive learning activities.

As an example of how to address questions of training frequency, some
federal agencies require all new employees to complete an orientation or
basic FEOSH course, which meets the OSHA FEOSH requirements on the
training elements common to all employee groups.  At these agencies, the
orientation or basic FEOSH course resides in an on-line system and it is
available at all times for the use of employees.  This initial or
orientation training is then coupled with agency-wide annual safety and
health training for all employees and any specific training, which is
necessary based on an employee’s position, duties and exposures.  The
annual agency-wide training is newly developed each year covering a
series of safety and health topics of current importance such as,
distracted driving, ergonomics, etc.  Each year’s announcement to
employees of the new annual training includes a reminder of the
“on-demand” availability of the basic orientation training for those
wishing a refresher.  This approach offers an effective means of
complying with OSHA requirements, and it is efficient with regard to
training budgets as well as employee time dedicated to training
activities.  Importantly, this example ensures that safety and health
training for Federal employees is a continuing learning process building
on OSHA requirements rather than a one-time event or static
“refresher” requirement to be fulfilled each year without provision
for new or enhanced topics. This approach also allows for training
related to new or emerging hazards and issues of importance to a given
agency or job task/function.  

All new employees must complete an orientation or basic FEOSH course,
which meets the OSHA issued guidance on training requirements.  This
orientation or basic FEOSH course resides in an on-line system and it
remains available at all times for the use of employees.  In subsequent
years after having completed the orientation FEOSH course, all employees
are required to take an agency-wide annual safety and health training
course.  This annual safety and health training may be specific
training, which is necessary based on an employee’s position, duties
and exposures; or it may be an annual agency-wide training which is
newly developed each year covering a series of safety and health topics
of current importance such as distracted driving, ergonomics, etc.  In
addition, each year’s announcement to employees of the need to
complete some form of annual safety and health training would include a
reminder of the “on-demand” availability of the basic orientation
training for those wishing a refresher on the standard FEOSH topics.

Appendix D to this guideline provides a table of the frequency of
baseline FEOSH training by relating initial and annual safety and health
training courses.

IV. Documentation & Assurance of Training

Certain standards require evidence of a formal training plan or training
materials, or both, as well as written documents certifying successful
completion of required training.  As an example, the standard for
process safety management of highly hazardous chemicals requires
employers to make sure each worker "has received and understood" the
required training.  In addition to this requirement for documentation,
employers also must keep a record of "the means used to verify that the
employee understood the training," which is a method of assurance.  The
language in OSHA’s FEOSH standard; however, is less specific about
either the need for a formalized program or records of employee
participation or achievement.  In OSHA’s FEOSH standard under some of
the job categories, we find that the training of employees should be,
“commensurate with the scope of their assigned responsibilities.” 
Further, OSHA states that agencies must “implement career development
programs” for safety and health specialists, and they must “include
both introductory and specialized courses” in the training of
employees who are representatives of employee groups.  To adequately
implement either of these two requirements, it is necessary some method
of documentation must be in place.  An interpretation that required
training provisions within OSHA’s FEOSH standard require agency’s to
document the training is a reasonable conclusion.  Accordingly, this
guideline requires the documentation of the required training
provisions. 

  

While an interpretation of the statements found in OSHA’s FEOSH
standard may be used to justify documentation of training, there also
are statements in the paragraphs on training, which describe the
activities or performance that is expected as a result of the training. 
These activities that the various employee groups must be able to
demonstrate proficiency in following instruction is a form of assurance.
 For example, supervisors must have training such that they are able to
“recognize and eliminate, or reduce, occupational safety and health
hazards in their working units.” Supervisors also are expected to be
trained to report hazards, investigate allegations of reprisal, and know
agency procedures for the abatement of hazards. Establishing a method or
means of assuring that employees understand the training, which they
receive is an acknowledgement of these responsibilities and a
demonstration of accountability and “good faith” in complying with
the Executive Order, the federal law and the OSHA standards.  In this
regard, Assistant Secretary Michaels April 28, 2010 memorandum to OSHA
regional administrators, “OSHA Training Standards Policy Statement,”
makes it quite clear that an employer “must instruct its employees
using both a language and vocabulary the employees can understand.” 

Documentation of employee training to meet the provisions of OSHA’s
FEOSH standard need not be separate from other employee training
records; however, it must be recorded in such a form as to be easily
retrievable and clearly identifiable as meeting the requirements of 29
CFR Part 1960.  

Likewise, there should be assurance employees have not only taken the
training, but that they have “understood” the training. Typically,
the first step is to define the learning objectives for the training. A
learning objective should specify the criteria used to determine whether
particular knowledge, skill, or ability has been attained. The criteria
should include the conditions under which the trainee is evaluated and
the standard of performance, which is acceptable for the learning
objective. The conditions of achievement of the learning objective(s)
may, for example, be successful completing of a question on a quiz
within the training or at the completion of training, and/or meeting a
standard of performance under a simulated or an actual work condition. 
Passing a quiz or demonstrating a particular skill, based on specified
learning objectives, also may be an effective way of determining whether
training is actually required. 

Assurance of the effectiveness of training is also enhanced by obtaining
the perspectives of the trainee, the trainer, the workplace, and/or the
organization.  These may be documented on forms developed by the agency.


V. Methods of Delivering Training

With few exceptions, current OSHA standards do not dictate methods to be
used in delivering the required training.  One standard on powered
platform operations (29 CFR 1910.66)) mentions pictorial methods can be
used instead of written work procedures in the training activity. 
Several others stipulate a portion of the training time to be a
“hands-on” or laboratory type learning experience.  More generally,
however, the “how to” of training is left to the discretion of the
agency.

Here the agencies should be given the latitude to implement the most
effective and efficient approach to training employees.  Some agencies
may elect to have several different methods of delivering the necessary
training.  However, the selection of a method should include a plan and
system for self-assessing the effectiveness of the method.  This would
ensure that a method, which is not effective, will be quickly altered or
changed. Assurance of the effectiveness of training methods also may be
enhanced by obtaining the perspectives of the trainee, the trainer, the
workplace, and/or the organization. These perspectives also may be
documented on forms developed by the agency. 

The method of delivering the training is very important.  Ineffective
methods often result in employees not having sufficient knowledge,
skills, or abilities to protect themselves.  Ineffective methods may
also contribute to developing cultures, which do not value truly
addressing health and safety issues.  Because agency leadership has the
responsibility for determining the best and most efficient use of
resources, they should be responsible for determining the most effective
and efficient methods to be used in delivering the required training.
Management’s review of perspectives of the trainee, the trainer, the
workplace, and/or organization officials may provide needed insights and
result in appropriate metrics associated with program validation.
However, in any case there must be an accountability aspect accompanying
this responsibility if consistency in training is to be achieved.  One
method of accountability would be for a portion of the OSHA required
annual FEOSH reporting to include specific information/data on agency
metrics used in gauging the effectiveness of such training. 

VI. Communications Plan

Any effort to establish consistency of federal agency safety and health
training across the federal agencies will require OSHA develop and issue
guidance as to the general content and frequency of such training.  This
guidance must then be clearly communicated to all federal agencies along
with any other expectations.    

Recommendations for communicating federal employee safety and health
training guidance to the federal agencies include: 

Requiring agencies to report on the consistency of their federal
employee safety and health training efforts in the required annual FEOSH
reports.  The OSH Act, E.O. 12196, and 29 CFR 1960.71 all have
requirements for federal agency heads to submit to the Secretary of
Labor an annual report on their agency's occupational safety and health
program.  OSHA can add to their existing reporting template, requests
for information about agency training, metrics for the training,
frequency of training, and others. This option would ensure agency heads
see this issue as a “reportable” item and it would improve the
likelihood that such training would continue to be funded. 

Letter/Memo to DASHOs – Every federal agency is required to appoint a
“Designated Agency Safety and Health Official” (DASHO) as required
by section 1.2 of E.O. 12196 and by 29 CFR 1960.6.  The Secretary of
Labor (or the Assistant Secretary of Labor for OSHA) may elect to send a
letter to agency DASHOs informing them of the issuance of guidelines for
federal employee safety and health training and asking for their
cooperation in ensuring consistency. 

Letter to Agency Heads - The Secretary of Labor (or the Assistant
Secretary of Labor for OSHA) may jointly or in coordination with the
Director of the Office of Personnel Management send a letter to agency
heads informing them of the issuance of guidelines for federal employee
safety and health training and ask for their cooperation in ensuring
consistency. 

Letter to OPM - The Secretary of Labor (or the Assistant Secretary of
Labor for OSHA) may send a letter to the director of OPM requesting they
use their communication avenues to notify agency heads, agency Human
Resources departments, and Employee Assistance Programs of the
establishment of a baseline for the training requirements in the current
FEOSH standard and ask for their cooperation in ensuring consistency.

VII. Oversight of Training  

OSHA should develop an oversight or verification process for FEOSH
training.  The primary objective in establishing such an oversight
process would be to ensure the required training is consistently
provided to every federal employee.  Such a process should improve
training quality and portability across agencies.  Such an oversight
program may be as fundamental as requesting that each agency DASHO
review and “verify” their agency’s FEOSH training met the OSHA
guidance.  OSHA could then use a random selection process to conduct
on-site spot-checks of a small sample of agencies as a means of
verifying conformance and consistency.  

VIII. Resources

 HYPERLINK "https://www.asse.org/cartpage.php?link=standards" ANSI/ASSE
Z490.1-2009, Criteria for Accepted Practices in Safety, Health, and
Environmental Training 

This standard establishes criteria for training administration and
management, development, delivery, evaluation, and documentation and
recordkeeping.  It also provides useful guidelines.

 HYPERLINK "https://www.asse.org/cartpage.php?link=standards"
https://www.asse.org/cartpage.php?link=standards 

 HYPERLINK
"https://netforum.avectra.com/eweb/shopping/shopping.aspx?site=neshta&we
bcode=shopping&prd_key=8730caa1-50d4-4272-acf1-be502a5331d3" Designing
and Delivering Effective Training ; Susan M. McMaster, CIT; NESHTA 2004

Provides principles for designing, delivering and evaluating workplace
training, to include guidance in instructional strategies, media
selection, delivery and testing techniques, and program validation

https://netforum.avectra.com/eweb/shopping/shopping.aspx?site=neshta&web
code=shopping&prd_key=8730caa1-50d4-4272-acf1-be502a5331d3

– Appendix A –

OSHA Required Training Listed by Employee Category or Group1

Employee group or category	REQUIRED training



“top management officials” - 1960.54

	

Four (4) basic items:

Sec. 19 of the OSH Act, 

E.O. 12196, 

29 CFR Part 1960, and 

Their Agency’s Safety & Health program. 





“supervisory employees” - 1960.55

	

In addition to the 4 basic  items1 “supervisory employees” must
receive training on:

Supervisory responsibility for safety & health 

Applicable S&H standards

Procedures for reporting hazards

Procedures for investigating allegations of reprisal

Procedures for hazard abatement.

Training on motivation of subordinates.





“safety and health specialists” - 1960.56	

In addition to the 4 basic  items1 “safety and health specialists”
must receive training on: 

Technical monitoring, testing, sampling, testing, design, etc.  

Hazard recognition, evaluation and control

Equipment and facility design

Analysis of accident, injury and illness data 

Career development plan/program





“safety and health inspectors” - 1960.57

	

In addition to the 4 basic  items1 “safety and health inspectors”
must receive training on:

preparation of reports and findings





“collateral duty safety and health personnel

     and committee members” - 1960.58

	

In addition to the 4 basic  items1 “collateral duty safety & health
personnel” must receive training on:

Procedures for reporting, evaluating and abating hazards; 

Procedures for investigating allegations of reprisal; 

Hazard recognition; and 

Identification and use of S&H standards. 





“employees and employee representatives”

    –  1960.59  	

In addition to the 4 basic items1 “employees” must receive training
which is: “appropriate to the work performed.”  

 In addition to the 4 basic items1 “employee representatives” must
receive “specialized training” in hazard recognition and in
workplace inspections.



1Each of the six major groups of employees addressed in 29 CFR 1960 are
required to be trained on 1) Sec. 19 of the OSH Act, 2) E.O. 12196, 3)
29 CFR Part 1960, and 4) their Agency’s Safety & Health program.

Note: Training items which are similar are highlighted with similar
colors to identify them.

– Appendix B –

CONTENT OF TRAINING

 BASELINE of FEOSH TRAINING ELEMENTS1

 (Proposed OSHA guidance - Agencies are responsible for initial/baseline
training of each of these elements)

Baseline TRAINING Elements



	

Section 19 of Public Law 91-596 (the OSH Act);

Presidential Executive Order 12196, (E.O. 12196); 

29 CFR 1960, Elements for Federal Employee Occupational Safety and
Health Programs; 

General awareness/orientation

Individual agency’s safety & health (S&H) program; 

How to identify applicable S&H standards; 

Procedures for reporting, evaluating & abating hazards; 

Procedures for reporting & investigating allegations of reprisal; 

Evaluation and abatement of hazards.  



	1 As required by OSHA’s FEOSH standard, 29 CFR Part 1960.

– Appendix C –

CONTENT OF TRAINING

Training NOT COVERED BY THE BASELINE of FEOSH TRAINING ELEMENTS1

(Proposed OSHA guidance – Agencies are responsible for the content,
deliver, etc. of each of the following elements.)   

Employee group or category	

SPECIAL training 





“top management officials” - 1960.54

	

The training required by OSHA’s FEOSH standard is covered by using the
baseline training elements for content of FEOSH training.



“supervisory employees” - 1960.55

	

The following training requirements are not covered by the  baseline of
FEOSH training elements:

Supervisory responsibility for safety & health:  Agencies will have to
provide additional agency-specific training on supervisory
responsibilities for safety & health.  

Training on motivation of subordinates.  OPM Position Classification
Standards for “supervisory” positions require employees in
supervisory positions to have some ability/skill in motivation of
subordinates; agencies will need to supplement their agency-specific
training with appropriate safety & health tng.





“safety and health specialists” - 1960.56	

The following training requirements are not covered by the  baseline of
FEOSH training elements: 

Technical monitoring, testing, sampling, testing, design, etc.; OPM
Position Classification Standards for “safety & health specialist”
positions require ability/skill in this area to qualify for the
position.  Agencies will have to provide additional training and update
or refresher training in this area.

Equipment and facility design; Agencies will have to provide
agency-specific & facility-specific training in this area.

Analysis of accident, injury and illness data; OPM Position
Classification Std.’s require these skills/abilities to qualify for
this position.  Agencies will have to provide additional training and
agency-specific training in this area.

Career development plan/program. Agencies will have to develop such
plans based on employee assignments and tasks, and provide additional
training as appropriate.





“safety and health inspectors” - 1960.57	

The following training requirements are not covered by the  baseline of
FEOSH training elements: 

Preparation of reports and findings.  OPM Position Classification
Std.’s require these skills/abilities to qualify for safety and health
inspector positions.  Agencies will have to provide additional training
especially on agency-specific procedures and protocols.  As agency
directives and requirements change, retraining will be necessary.



“collateral duty safety and health personnel

     and committee members” - 1960.58

	The training required by OSHA’s FEOSH standard is covered by using
the baseline training elements for content of FEOSH training. 
Additional training and updates or refresher training may be added by
individual agencies to ensure employees know and understand agency
safety and health procedures and programs.





“employees and employee representatives”

    –  1960.59  

	

The following training requirements are not covered by the  baseline of
FEOSH training elements: 

For “employees” training is to be: “appropriate to the work
performed,”” which will include training beyond the baseline
elements.  Additional training should be based on an evaluation of
employee assignments and potential exposure to hazards.

“Employee representatives” must receive “specialized training”
in hazard recognition and in workplace inspections, which is beyond that
listed in the baseline elements.

  

1 As required by OSHA’s FEOSH standard, 29 CFR Part 1960.

.

– Appendix D –

FREQUENCY OF TRAINING

Employee Group or Category	

Frequency of Training





All new employees – either those new to federal employment or those
transferring from another federal agency.	

Annual safety and health training to consist of:

An initial safety and health training course covering of the baseline
FEOSH elements and provided within the first two weeks of employment;
and thereafter followed by

Annual safety and health training courses which build on the elements of
the initial course and focus on current safety issues, tasks and/or
assignments. 

 



  

OCCUPATIONAL SAFETY AND HEALTH TRAINING GUIDELINES

 FOR FEDERAL EMPLOYEES

Appendix A 

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