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May 2, 1994

C.K. Genge, CSP
Safety and Health Program Supervisor
Corning Incorporated
TY-US-02-03
Corning, New York 14831

Dear Mr.Genge:

Thank you for your letter of March 18, regarding the Occupational Safety and Health Administration's (OSHA) requirements for refresher training. Your specific question is whether passing a "properly designed test" can be used in lieu of annual refresher training.

In circumstances when the hazard and assigned duty remain the same, the use of a properly designed, annual written test may suffice to meet annual training requirements. A written test by itself may not be sufficient, however, for training that requires a demonstration of competency (e.g., donning an doffing of personal protective equipment that is infrequently used). The intent of training (including annual and refresher) is to provide employees with the knowledge and skills necessary to perform their job duties and responsibilities with minimal risk to their safety and health.

We hope this information is helpful.

Sincerely,



H. Berrien Zettler, Deputy Director
Directorate of Compliance Programs

March 18, 1994

Mr. Michael Silverstein
Director
Directorate Of Policy
U.S. Department of Labor, OSHA
200 Constitution Avenue N.W.
Washington, D.C. 20210

Dear Mr. Silverstein,

Since its inception the Occupational Safety and Health Administration has emphasized the importance of using training in the prevention of accidents and exposures of workers to injurious materials. In some cases specific training is required by Occupational Safety and Health Standards. Depending on the worker's potential for exposure to hazards, there are requirements for certain types of training to be conducted on an annual basis. When the requirements are conscientiously followed there are a number of employees who receive the same information every year. This redundancy is boring for the participants, costly for the employers, and does not accomplish the intended purpose.

My question is this:

When an individual has received levels of training that is sufficient for them to pass a properly designed test of the information they are expected to know, can a passing grade on the test be substituted for a repetition of the required annual training.

Your prompt response in written form is requested. If there are any questions, I can be contacted at (607) 974-8003. Thank you for your attention to this matter.

Sincerely,



C.K. Genge, CSP
Safety and Health Program Supervisor
Corning Incorporated
TY-US-02-03
Corning, New York 14831