Even among funeral homes who do diligent training every year, failure to do the right kind of safety training is rampant. In some cases, they over-train. This is not a citable offense. It does no harm. In other cases, they train the wrong people. Again, this is not a penalty. Some over-document while others under-document. Even that is okay if the employer provides the required employee safety training. Let’s dig inside OSHA training requirements.

  OSHA’s required annual training is a different animal than initial employee training. It is only for employees using respirators, or those exposed to formaldehyde, blood, or needles. After that, state regulations come into play. A few states require annual Hazard Communications training. Federal OSHA does not. In federal OSHA, training is required whenever a new hazard is introduced into the workplace.

  I see errors of a different kind. Most are meaningless but they might surprise you. Many employers in this industry want to excel at compliance. Some insists that all employees monitor all the annual training that is offered. What purpose does it serve for a secretary to sit in on formaldehyde safety training? It shows the employer is generous with employee time? More than a few are not. Do I think that kind of broad safety training is beneficial? No. I would prefer that employers take the two hours a secretary dedicates to bloodborne pathogen, needle stick and formaldehyde safety training and trade it for one or two hours of office safety training. While that would make more sense to me, putting the secretarial pool through the chain of infection of HIV is not something an OSHA inspector would ever criticize.

  Over-compliance is common but it is never a problem with me. Do you document your annual formaldehyde training? It’s fine if you do but you cannot find anything in the formaldehyde standard that requires you to document annual formaldehyde training. Even so, I recommend you document it. Interestingly, the bloodborne pathogen standard does require annual documentation. It even gets into documenting multiple areas. In the real world, one simple documentation does the trick.

  There is a reason I haven’t written about this in twenty-five years of regulatory consulting. No one ever got cited for giving employees annual hazard communications training when it was not required. No one has ever been cited for unnecessarily documenting formaldehyde training. The most frequent training related citation is for not giving employees the required training. Next, it is for not giving employees the required training in the required time. That means every twelve months (give or take a few days). If you stretch annual requirement to thirteen months, it invites a mild citation.

  In summary, over-training and over-documenting is nothing to worry about. Now if you happen to have a problem keeping secretaries, you may want to rethink requiring them to participate in the annual bloodborne pathogen safety training. It’s just a thought. Note to employers: Don’t forget to give 2017 annual renewal training to your exposed employees.