• Record Type:
    OSHA Instruction
  • Current Directive Number:
    TED 01-00-012
  • Old Directive Number:
    TED 1.12A
  • Title:
    Training Program for OSHA Compliance Personnel
  • Information Date:
Archive Notice - OSHA Archive

NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.

"This document was published prior to the publication of OSHA's final rule on Ergonomics Program (29 CFR 1910.900, November 14, 2000), and therefore does not necessarily address or reflect the provisions set forth in the final standard."


OSHA Instruction TED 1.12A July 7, 1992 Office of Training and Education

Subject: Training Program for OSHA Compliance Personnel

A. PURPOSE. This instruction provides National, Regional, and Area Office personnel with policy and guidelines for implementation of technical training programs for OSHA compliance personnel.

B. SCOPE. This instruction applies OSHA-wide.

C. REFERENCES.

1. OSHA Instruction PAE 2.1C, November 18, 1991, Field Audit Program.
2. OSHA Instruction COM 4.1, October 23, 1991, OSHA Training Institute Board of Directors.
3. OSHA Instruction STP 2.22A, CH-2, January 29, 1990, State Plan Policies and Procedures Manual.
4. OSHA Notice TED 1, OSHA Training Institute Schedule of Courses and Registration Requirements, which is revised annually.

D. CANCELLATION. OSHA Instruction TED 1.12, Training Operations Program for OSHA Compliance Personnel, February 9, 1987, is cancelled.

E. ACTION. Regional Administrators and Area Directors shall ensure that the procedures established in this instruction are followed.

1. Regional Administrators shall submit the names of new- hire compliance personnel as they come on board to the Registrar, OSHA Training Institute.
2. The Registrar, OSHA Training Institute, shall enroll each new-hire compliance officer in the next available sequence of mandatory courses and provide the Regional Administrator with a schedule of classes in which each new hire is enrolled.

OSHA Instruction TED 1.12A July 7, 1992 Office of Training and Education

3. The implementation of this training program shall be monitored through Regional audits of Area Offices.

F. FEDERAL PROGRAM CHANGE. This instruction describes a Federal program change that affects State programs. Each Regional Administrator shall:

1. Ensure that this change is forwarded to each State designee, using a format consistent with the Plan Change Two-way Memorandum in OSHA Instruction STP. 2.22A, CH-2, State Plan Policies and Procedures Manual, Appendix P.
2. Explain the content of the change to the State designees as requested.
3. Advise the State designees that each State must have a formal, documented training program in place for its safety and health compliance personnel by either adopting Federal OSHA training policy in Paragraphs J. K., and L. of this instruction or by developing an alternative policy at least as effective as the Federal OSHA training policy.
4. Ensure that State designees acknowledge receipt of this Federal program change in writing to the Regional Administrator as soon as the State's intention is known, but not later than 70 calendar days after the date of issuance (10 days for mailing and 60 days for response). This acknowledgment must include a description either of the State's plan to implement the change or of the reasons why the change should not apply to that State.
5. Ensure that the State designees submit a plan supplement in accordance with OSHA Instruction STP 2.22A, State Plan Policies and Procedures Manual, as appropriate, following the established schedule that is agreed upon by the State and Regional Administrator to submit non-Field Operations Manual/OSHA Technical Manual Federal program changes.
a. If a State intends to follow the training requirements in Paragraphs J., K., and L. with only minor revisions, the State must submit either a revised version of this reference State law, regulations, and administrative structure, or a cover sheet

2

OSHA Instruction TED 1.12A July 7, 1992 Office of Training and Education

describing how references in this instruction correspond to the State's structure. The State's Memorandum may fulfill the plan supplement requirement if the appropriate documentation is provided.
b. If the State adopts an alternative to Federal guidelines, the State's submission must identify and provide a rationale for all substantial differences from Federal guidelines to allow OSHA to determine whether a different State policy and procedure is as effective as comparable Federal guidelines. States have six months from the date of this instruction to submit a plan supplement describing their training program for safety and health compliance officers.
6. Inform the State designees that the Region and OSHA Training Institute will provide technical assistance and resource materials to aid the State in the development and implementation of training plans and encourage the States to utilize the training courses available from the OSHA Training Institute to meet their training requirements. Procedural arrangements should be made between the State and the Region to facilitate the State adoption and implementation of the change and to ensure that each individual State's training goals and objectives are met.
7. Inform the State designees that they may participate in the evaluation of the effectiveness of the revised training program at the end of the second year of operation.
8. Ensure that routine monitoring activities are used to determine if this change has been implemented by actual performance.

G. SIGNIFICANT CHANGES. This instruction describes the revised training program for new-hire OSHA compliance personnel. Significant changes are summarized below.

1. During the developmental period, new-hire compliance personnel will follow one of the tracks represented by the following three disciplines: safety, health, or construction.

3

OSHA Instruction TED 1.12A July 7, 1992 Office of Training and Education

2. All new-hire compliance personnel will be required to attend #100 Initial Compliance Course. This two-week course provides an introduction to OSHA history, policies, and procedures. Safety officers and industrial hygienists will attend this course together.
3. After completing #100 Initial Compliance Course, each new hire will attend one of the following two-week standards courses: #105 Introduction to Safety Standards for Safety Officers, #125 Introduction to Health Standards for Industrial Hygienists, or #200 Construction Standards.
4. Each new hire will track his/her progress during the developmental period. A sample format is provided in Appendix A of this instruction.

H. INTRODUCTION AND OBJECTIVES.

1. INTRODUCTION. In order to meet the continuing need for highly trained compliance safety and health officers (CSHO's), the Occupational Safety and Health Administration (OSHA) has developed a training program for new-hire and experienced compliance personnel. The training program is designed to provide a series of training courses that are supported and interspersed with self-instructional activities and on-the-job training to ensure that compliance personnel are able to apply technical information and skills to their work. The elements of the training program outlined in this instruction are not meant to be prerequisites for advancement. To ensure consistent, high-quality training, it is important that all of the activities associated with this training program be administered in a uniform manner in all Regions.
2. DEVELOPMENTAL PERIOD.
a. The basic training program for new hires is to be completed during a developmental period. The developmental period is the time it takes a new-hire CSHO to complete the formal, self-study, and on-the-job training requirements outlined in this instruction. This developmental period will be approximately two years in length.
b. The following basic courses shall be completed

4

OSHA Instruction TED 1.12A July 7, 1992 Office of Training and Education

within the first year of the developmental period:
(1) #100 Initial Compliance Course;
(2) Either #105 Introduction to Safety Standards for Safety Officers, or #125 Introduction to Industrial Hygiene Standards for Industrial Hygienists, or #200 Construction Standards; and
(3) #141 Inspection Techniques and Legal Aspects.
c. The developmental period for an experienced new hire may be shorter, based on the individual's background and progress.

3. OBJECTIVES. Upon completion of the elements of the developmental training program the CSHO will demonstrate:

a. A working knowledge of the fundamentals of hazard recognition, evaluation, and control.
b. Adequate knowledge of the implementation of engineering controls, abatement strategies, and the interpretation of data.
c. A reasonable comprehension of basic industrial processes and the ability to make quantitative observations and measurements.
d. The ability to properly calibrate and use measuring instruments.
e. The ability to perform solo inspections or participate as a member in team inspections in most types of industries.
f. Knowledge of regulations and laws that involve safety and health in the workplace.
g. The ability to present inspection data efficiently in a legal proceeding.
h. The ability to make a referral to other appropriate industrial hygienists or safety officers.

5

OSHA Instruction TED 1.12A July 7, 1992 Office of Training and Education

I. ORGANIZATIONAL TRAINING RESPONSIBILITIES.

1. NATIONAL OFFICE. National Office Directors shall support the training program, as appropriate, by providing resources, supplying current information on the status of agency programs, ensuring program consistency, and auditing Regional Office training programs.
2. OFFICE OF TRAINING AND EDUCATION. The Director, Office of Training and Education, is responsible for providing programs to educate and train OSHA compliance personnel in the skills and knowledge required to perform their duties. Specific responsibilities include:
a. Providing the planning function for agency technical training initiatives.
b. Developing training materials and programs.
c. Conducting needs assessments to identify the training needs of compliance personnel.
d. Conducting evaluations of training programs for compliance personnel.
3. THE OSHA TRAINING INSTITUTE. The Director, OSHA Training Institute, is responsible for the delivery of short-term occupational safety and health training. Specific responsibilities include:
a. Conducting programs of instruction for Federal and State compliance officers.
b. Participating in the development of course outlines, detailed lesson plans, and other educational aids necessary to carry out Institute training programs.
4. THE OSHA TRAINING INSTITUTE BOARD OF DIRECTORS. The OSHA Training Institute Board of Directors shall advise and make recommendations concerning the mission, functions, policies, planning, and resources of the OSHA Training Institute in accordance with the provisions of OSHA Instruction COM 4.1, OSHA Training Institute Board of Directors.

6

OSHA Instruction TED 1.12A July 7, 1992 Office of Training and Education

5. REGIONAL OFFICE.
a. REGIONAL ADMINISTRATOR. The Regional Administrator directs the execution of the Region-wide training and education program through the Assistant Regional Administrator for Training, Education, Consultation, and Federal Agency Programs (ARA/TECFAP).
b. ARA/TECFAP. The ARA/TECFAP directs the execution of the Region-wide training and education program through the Regional Training Officer.
c. REGIONAL TRAINING OFFICER. The Regional Training Officer assists the ARA/TECFAP in coordinating the management of all Region-wide training and education programs. The Regional Training Officer serves as the focal point in each Region for ensuring the successful implementation of the training program for Regional compliance personnel as outlined in this instruction. Specifically, the Regional Training Officer shall:
(1) Provide guidance and assistance concerning information contained in this instruction.
(2) Assist in providing resource material and current training information to Area Directors and Supervisors/Assistant Area Directors concerning the implementation of the objectives of the training program.

(3) Evaluate-and monitor all records of training.
6. AREA OFFICE.
a. AREA DIRECTOR. The Area Director has the overall responsibility for ensuring and facilitating the development and training of new-hire and experienced CSHO's under his/her supervision. The Area Director directs the execution of the training program through the Supervisor/Assistant Area Director.
b. SUPERVISOR/ASSISTANT AREA DIRECTOR. The Supervisor/Assistant Area Director (AAD) serves as the focal point in the Area Office for ensuring

7

OSHA Instruction TED 1.12A July 7, 1992 Office of Training and Education

the successful implementation of the training program for compliance personnel as outlined in this instruction. Specifically, the Supervisor /AAD shall:
(1) Ensure the professional development of CSHO's under his/her supervision.
(2) Identify, through the Individual Development Plan (IDP) process, training needs of CSHO's assigned to his/her supervision and plan and coordinate all training.
(3) Provide and coordinate instruction, assistance, and guidance that is consistent with the IDP process for CSHO's to meet the training program objectives as outlined in this instruction.
(4) Review and discuss training progress with each CSHO under his/her supervision during the mid-year and annual performance reviews.
(5) Assign, as needed, senior CSHO's to assist in the on-the-job training of new hires.
c. COMPLIANCE SAFETY AND HEALTH OFFICER (CSHO). The CSHO has the responsibility to perform to the best of his/her ability in all technical training programs. Specifically, the CSHO shall:
(1) Participate in the planning of developmental activities.
(2) Complete all designated training sessions, courses, and assignments.
Each new-hire CSHO shall maintain a progress record or list of training progress. A sample format is provided in Appendix A for guidance.

J. PROFESSIONAL DEVELOPMENT OF NEW-hIRE COMPLIANCE PERSONNEL.

1. INTRODUCTION. The purpose of the training program is to provide a wide range of training opportunities and learning experiences to assist CSHO's in their successful professional development. A flexible

8

OSHA Instruction TED 1.12A July 7, 1992 Office of Training and Education

program that incorporates self-paced learning has been developed to accommodate the varying levels of experience and competence encountered in new hires. However, certain basic training requirements for all compliance personnel are specified to provide uniformity in regard to specific skill and knowledge requirements.
a. The training program is designed to:
(1) Meet the needs of CSHO's with highly diverse academic backgrounds and experience.
(2) Incorporate essential requirements that will be monitored and evaluated but yet provide flexibility for managers in implementing the program.
(3) Provide guidance and appropriate training materials to managers.
b. The training program provides a well articulated progression of training requirements for new-hire personnel. The elements of the program include formal training at the OSHA Training Institute and informal training such as self-study and on-the-job training (OJT).
2. INTRODUCTORY TRAINING REQUIREMENTS. The following items are prerequisites to attending #100 Initial Compliance Course.
a. INFORMATIONAL PROGRAM. An informational program must be provided to all new-hire CSHO's within the first month of employment. The program shall be administered by Regional or Area Office personnel as designated by the Regional Administrator. Information on National, Regional, and Area Office organization, administration, policies, and procedures is included in the program.
(1) The informational package shall include, at a minimum:
(a) Information on the U. S. Department of Labor.

9

OSHA Instruction TED 1.12A July 7, 1992 Office of Training and Education

(b) An introduction to the OSHA program including history, purpose, program mix, role of CSHO, etc.
(c) Information on the Regional and Area Office structure, the Area Office's procedures, and the Area Office library.
(d) Information on acronyms commonly used in the agency.

(e) Information on IDP development.
(f) Handout materials such as organizational chart, Field Operations Manual, standards, directives, personal protective equipment, and instruments.
(2) The Regional Administrator is responsible for ensuring that the following items of the information package are developed and provided:
(a) Regional Office organizational chart and overview of sectional functions.
(b) Information on Area Office structure and procedures.

(c) Copies of IDP's.

(d) Handout materials.
(e) Information specific to each Regional or Area Office as appropriate.
(3) The Office of Training and Education shall provide the remainder of the informational package materials.
b. OCCUPATIONAL SAFETY AND HEALTH ACT (OSH Act) SELF- STUDY. Each CSHO is required to complete a self- study on the OSH Act prior to attending #100 Initial Compliance Course. The purpose is to familiarize the CSHO with the basic requirements of the OSH Act. This program, developed by the Office of Training and Education and distributed

10

OSHA Instruction TED 1.12A July 7, 1992 Office of Training and Education

by the Regional Office, shall be administered at the Area Office level.
c. FIELD OPERATIONS MANUAL (FOM) SELF-STUDY. Each CSHO is required to complete a self-study program on the FOM prior to attending #100 Initial Compliance Course. The FOM provides necessary information on basic inspection procedures. The purpose is to prepare the CSHO for the Initial Compliance Course. This program, developed by the Office of Training and Education and distributed by the Regional Office, shall be administered at the Area Office level.
d. IMIS FORMS OSHA-1 OSHA-1A, OSHA-1B, and OSHA-1B(IH) SELF-STUDY. Each CSHO is required to complete a self-study program on the most commonly used IMIS forms, OSHA-1, OSHA-1A, OSHA-1B, and OSHA-1B(IH) (for industrial hygienists only), prior to attending #100 Initial Compliance Course. The purpose is to familiarize the CSHO with the IMIS forms in preparation for the Initial Compliance Course. This program, developed by the Office of Training and Education and distributed by the Regional Office, shall be administered at the Area Office level.
3. OSHA TRAINING INSTITUTE. New-hire CSHO's shall follow one of three tracks during the developmental period: safety, health, or construction. Figure 1 illustrates the training sequence for new hires. The following courses are required during a CSHO's developmental period.
a. #100 INITIAL COMPLIANCE COURSE. Each new-hire CSHO is required to attend this training course. Attendance is permitted only after having completed the prerequisite self-study programs. The purpose of this course is to provide new CSHO's with a working knowledge of OSHA policies, programs, and procedures; the Field Operations Manual; and an understanding of occupational safety and health programs. New CSHO's must

11

OSHA Instruction TED 1.12A July 7, 1992 Office of Training and Education

Figure 1
+-----------------------------------------+ |Training Trace for Compliance Personnel | +----------------------+------------------+ +-------------------+---------------+ | #100 Initial Compliance Course * | +-------------------+---------------+ +-------------------------+-----------------------+ +------+--------+ +-------------+------------+ +--------+----------+ | Safety Track | |Industrial Hygiene Track | |Construction Track | +------+--------+ +-------------+------------+ +--------+----------+ +------+-------------++----------+-----------+ +---------+---------+ |105 Introduction to || #125 Introduction to | | #200 Construction | |Safety Standards for|| Industrial Hygiene | | Standards * | |Safety Officers * || Standards for IH's * | | | +------+-------------++----------+-----------+ +---------+---------+ +------+----------+ +----------+-------+ +---------+---------+ |#141 Inspection | | #141 Inspection | | #141 Inspection | |Techniques and | | Techniques and | | Techniques and | |Legal Aspects * | | Legal Aspects * | | Legal Aspects * | +------+----------+ +----------+-------+ +---------+---------+ +------+--------------+ +--------+------------++---------+------------+ |#121 Intro. to | |#101 Safety Hazard || #121 Intro. to | |Industrial Hygiene | |Recognition for || Industrial Hygiene | |for Safety Personnel | |Industrial Hygienists||for Safety Personnel | | -or- | | -or- || -or- | |#200 Construction | |#200 Construction || #105 Intro. to | |Standards | |Standards || Safety Standards for | | | | || Safety Officers | +-------+-------------+ +--------+------------++---------+------------+ +-------+-----------+ +---------+----------+ +---------+----------+ |Technical Courses | | Technical Courses | | Technical Courses | | Select 2 | | Select 2 | | Select 2 | | From Below | | From Below | | From Below | +-------+-----------+ +---------+----------+ +---------+----------+ +-------+--------------+ +-------+--------------++-------+----------------+ |Hazardous Materials | | Noise ||Cranes in Construction | | Electrical | | Ventilation || Excavation | |Machine Guarding | | Respirator || Tunneling | |Fire Protection | | Toxicology || Scaffolding | |Cranes for General Ind| | Ergonomics ||Fall Protection | | Maritime | | Maritime || Maritime | |State Plan Monitoring | |State Plan Monitoring || State Plan Monitoring | |Basic Accident Invest.| |Basic Accident Invest.|| Basic Accident Invest. | +----------------------+ +----------------------++------------------------+

Note: * To be completed during first year of the developmental period.

12

OSHA Instruction TED 1.12A July 7, 1992 Office of Training and Education

complete this course prior to attending any other Training Institute courses.

NOTE: This course may not be waived.
b. STANDARDS COURSE. After having completed the Initial Compliance Course, each new-hire CSHO is required to attend either #105 Introduction to Safety Standards for Safety Officers, #125 Introduction to Health Standards for Industrial Hygienists, or #200 Construction Standards during the developmental period. The purpose of these courses is to provide new-hire CSHO's with a thorough introduction to the organization and content of the standards and to hazard recognition and documentation.
NOTE: Attendance at one of the standards courses may not be waived.
c. #141 INSPECTION TECHNIQUES and Legal Aspects. Each new-hire CSHO is required to attend this training course during the developmental period. The purpose of this course is to provide new CSHO's with an understanding of basic communication skills, formal requirements and processes of the legal system, and investigative techniques related to OSHA compliance activity.

NOTE: This course may not be waived.
d. CROSSOVER TRAINING. Recognizing the need for CSHO's to be familiar with general concepts of both safety and health, each new hire is required to complete training in another discipline during the developmental period. The decision on which crossover course to take shall be made by the CSHO's supervisor based on the CSHO's safety or health discipline and educational needs as well as Area Office requirements.
CSHO's on the safety or construction track are encouraged to attend the introduction to health course; whereas industrial hygienists are encouraged to attend the introduction to safety course. New-hire CSHO's must attend one of the following during the developmental period. However, if

13

OSHA Instruction TED 1.12A July 7, 1992 Office of Training and Education

resources permit, the completion of both courses prior to enrollment in other, more specific technical courses is recommended.
SAFETY
#121 Introduction to Industrial Hygiene for Safety Personnel, or #200 Construction Standards
HEALTH
#101 Safety Hazard Recognition for Industrial Hygienists, or #200 Construction Standards
CONSTRUCTION
#121 Introduction to Industrial Hygiene for Safety Personnel, or #105 Introduction to Safety Standards for Safety Officers
e. TECHNICAL COURSES. Each new-hire CSHO is required to attend at least two courses specific to his/her discipline during the developmental period. The purpose of these training courses is to provide the CSHO with technical knowledge, skills, and information on hazard recognition as related to OSHA requirements. The specific courses will be determined by the CSHO's supervisor based on individual need during the IDP process. These courses shall be selected from the following basic core courses.
SAFETY
#102 Basic Accident Investigation for CSHO's #153 State Plan Monitoring #201 Hazardous Materials #203 Basic Electrical Principles #204 Machinery and Machine Guarding Standards #206 Maritime Standards #207 Fire Protection and Life Safety #208 Cranes and Material Handling for General Industry #309 Electrical Standards

14

OSHA Instruction TED 1.12A July 7, 1992 Office of Training and Education

HEALTH
#102 Basic Accident Investigation for CSHO's #153 State Plan Monitoring #206 Maritime Standards #220 Industrial Noise #221 Principles of Industrial Ventilation #222 Respiratory Protection #223 Industrial Toxicology #225 Principles of Ergonomics
CONSTRUCTION
#102 Basic Accident Investigation for CSHO's #153 State Plan Monitoring #205 Cranes and Material Handling for Construction #206 Maritime Standards #301 Excavation, Trenching and Soil Mechanics #302 Tunneling and Underground Operations #308 Principles of Scaffolding #311 Fall Arrest Systems
4. AREA OFFICE: SELF-STUDY AND ON-THE-JOB TRAINING (OJT). This training program incorporates alternative modes of instruction including self-instructional techniques and OJT assignments with supervision. The OJT and self-study programs are designed to reinforce formal classroom training.
a. All new-hire CSHO's require training to perform their jobs effectively. In this regard, self study and OJT are essential supplements to formal classroom and. laboratory instruction. Both methods of instruction are needed to equip CSHO's to carry out their duties and responsibilities effectively.
(1) SELF-STUDY. Self-study involves training in the Area Office that will aid in preparation for formal training and course work.
(2) On-the-Job Training. On-the-job (OJT) training relates principles and theories to work skills that are then taught and applied in the field and office environment.

15

OSHA Instruction TED 1.12A July 7, 1992 Office of Training and Education

b. Self-study and OJT assignments shall be provided concurrently with formal training to emphasize and complement material covered in formal training courses. Time allotted to accomplish self-study and OJT assignments should be compatible with the new-hire CSHO's current knowledge, skill, and experience levels. The employee's supervisor shall verify the CSHO's ability to successfully complete self-study and OJT assignments.
c. The expertise and judgment of the employee's supervisor is required when assessing a CSHO's progress during this training program and the IDP process. The supervisor must ensure that the CSHO is ready to perform an assigned task. This program is flexible enough to afford the CSHO time for proper sequencing of training. Training assignments may also be supplemented by other task assignments as deemed necessary by the supervisor.
d. Training in the following subject areas, at a minimum, is to be accomplished through both self-study and OJT assignments.

(1) Hazard recognition overview.
(2) Inspection procedures.
(3) Standards:
General Industry Construction Maritime Agricultural Other Regulations and Procedures

(4) Field Operations Manual.
(5) IMIS Forms Manual.

(6) OSHA Directives System.
(7) OSHA Technical Manual.

(8) Common industrial processes.

16

OSHA Instruction TED 1.12A July 7, 1992 Office of Training and Education

(9) Basic elements of a good safety and health/accident prevention program.
(10) Standard Alleged Violation Elements (SAVE's) Manuals:
Regulatory and General Industry Construction Maritime
(11) Instrumentation.

(12) OSHA Computerized Information System (OCIS).
(13) Report writing.

(14) Standards from other sources.
American National Standards Institute National Electrical Code National Fire Protection Association American Conference of Governmental Industrial Hygienists Industrial Agency for Research on Cancer National Toxicology Program
e. This training must be completed within the developmental period. Although expertise in areas such as hazard recognition and industrial processes requires long-term, continuing education, it is expected that a solid foundation of information related to these topics will be presented during this time.
f. Instructional methods such as the use of audiovisual aids, reading materials, case file review, staff meetings, and inspection activity may be used by the employee's supervisor to assign the required topics. Appendix B of this instruction lists resource materials that may be used by the supervisor to assign self-study programs to CSHO's.
g. It is recommended that CSHO's be allowed to experience a variety of inspection activities in manufacturing, construction, and maritime when accompanying a senior level CSHO in the field.

17

OSHA Instruction TED 1.12A July 7, 1992 Office of Training and Education

Each new-hire CSHO should also have experience in establishments with different Standard Industrial Classification (SIC) codes and should be assigned to both safety officers and industrial hygienists.
5. WAIVER CONDITIONS. The training program outlined in this instruction is mandatory during a CSHO's developmental period.
a. Specifically, all prerequisites must be successfully completed before attendance at #100 Initial Compliance Course. In addition, one of the designated standards courses and #141 Inspection Techniques and Legal Aspects are to be completed during the first year of the CSHO's developmental period. At least two technical courses and one crossover training course must be completed before the CSHO is considered to have completed the developmental period.
b. If a new-hire CSHO has substantial prior safety or health experience and the required formal training program does not meet his/her needs, the employee's supervisor shall design a developmental plan of formal training, in conjunction with the IDP process, that is consistent with the CSHO's background. Any revised formal training plan developed for an individual CSHO shall be approved in accordance with the waiver procedure outlined below in Paragraph J.5.c. When a revised formal training plan is developed and approved, additional requests for waivers from specific mandatory courses are not required.
c. Any waivers from the mandatory program can be granted only by the Regional Administrator after consultation with the Area Director and the ARA/TECFAP. Waiver requests shall be submitted in writing by the Area Director to the Regional Administrator and shall take into consideration how the CSHO has acquired the levels of knowledge, skills, and abilities to perform his/her duties. The Regional Administrator's response to the waiver request shall also be in writing.

18

OSHA Instruction TED 1.12A July 7, 1992 Office of Training and Education

K. MONITORING THE TRAINING PROGRAM. Monitoring the CSHO's progress through the developmental period is critical to ensure success of the training program. Monitoring provides information to the CSHO's supervisor regarding the benefits and effectiveness of the training received. In addition, it provides information on the ability of the CSHO to achieve training goals and objectives. Both the employee's supervisor and the Regional Training Officer play major roles in the monitoring process.

1. The employee's supervisor shall ensure that each CSHO has completed the necessary prerequisites before attending mandatory OSHA training courses.
2. The employee's supervisor shall review the CSHO's performance of required self-study and OJT assignments.
3. The employee's supervisor shall conduct a review with the new-hire CSHO following each required self-study and OJT inspection activity. This review provides the supervisor with information on the progress of the CSHO and can assist in identifying areas requiring further training.
4. When the employee's supervisor determines that the new-hire CSHO has sufficient experience to participate fully in developing the actual case file, the OJT review may be discontinued.
5. The Course Evaluation section of DL Form 1-101, Training Authorization and Evaluation Form, is used to document course completion. The DL Form 1-101 will be returned to the CSHO upon completion of a course. The CSHO and his/her supervisor shall complete the Course Evaluation section and return the form to the OASAM Training Office in accordance with Regional procedures.
6. The Regional Training Officer shall monitor Area Office implementation of the training program outlined in this instruction through review of training documents and through assisting in Regional audits of Area Offices.

L. MAINTENANCE OF KNOWLEDGE AND SKILLS OF CSHO's BEYOND THE DEVELOPMENTAL PERIOD.

1. The agency recognizes that CSHO's require additional training each year to enable them to keep abreast of

19

OSHA Instruction TED 1.12A July 7, 1992 Office of Training and Education

current occupational safety and health issues and developments.
2. At a minimum, each CSHO is required to attend a safety and health related course once every three years. If a Training Institute course has changed significantly during the years, a CSHO is permitted to repeat the course.
3. Participation in training courses or programs shall be consistent with the CSHO's IDP.
4. CSHO's are encouraged to pursue other training opportunities that are available within the Department of Labor and elsewhere.

M. EVALUATION. An evaluation of the effectiveness of this revised training program shall be conducted at the end of the second year from the effective date of the instruction. Staff from the Office of Training and Education shall interview Area Directors, Supervisors, Assistant Area Directors, CSHO's, and designated State 18(b) personnel who have participated in the program to determine whether this instruction provides a feasible and effective technical training plan for compliance personnel and to obtain suggestions for program improvement. Based on the results of the interviews, additional evaluation studies may be developed.

Dorothy L. Strunk Acting Assistant Secretary
Distribution: National, Regional, and Area Offices Compliance Officers State Designees 7(c)(1) Project Managers

20

OSHA Instruction TED 1.12A July 7, 1992 Office of Training and Education

Appendix A
New-Hire CSHO's Training Plan Progress Report

A. INTRODUCTORY TRAINING REQUIREMENTS. DATE

COMPLETED 1. Initial interview including __________
discussion of position description and performance evaluation.
2. Development of training schedule, IDP. __________
3. Receipt of standards and manuals. __________
4. Receipt of credentials. __________
5. Review of ethics and conduct of __________
Department of Labor employees.
6. Receipt of personal protective equipment. __________
7. Receipt of inspection equipment. __________
8. Review of informational program. __________

B. SELF-STUDY PROGRAMS.

1. OSH Act self-study. __________
2. FOM self-study. __________
3. IMIS Forms 1, 1A, 1B, 1B(IH) self-study. __________

C. ON-THE-JOB TRAINING ACTIVITIES.

1. Review of General Industry Standards and related hazard recognition.
a. Subpart C, General Safety and Health __________
Provisions.
b. Subpart D, Walking-Working Surfaces. __________
c. Subpart E, Means of Egress. __________
d. Subpart F, Powered Platforms, Man- __________

lifts and Vehicle-Mounted Platforms.

A-1

OSHA Instruction TED 1.12A July 7, 1992 Office of Training and Education

e. Subpart G, Occupational Health and __________
Environmental Control.
f. Subpart H, Hazardous Materials. __________
g. Subpart I, Personal Protective __________
Equipment.
h. Subpart J, General Environmental __________
Controls.
l. Subpart K, Medical and First Aid. __________
j. Subpart L, Fire Protection. __________
k. Subpart M, Compressed Gas and __________
Compressed Air Equipment.
l. Subpart N, Materials Handling and __________
Storage.
m. Subpart O, Machinery and Machine __________
Guarding.
n. Subpart P, Hand and Portable Powered __________

Tools and Other Hand Held Equipment.
o. Subpart Q, Welding, Cutting, and __________
Brazing.
p. Subpart R, Special Industries. __________
r. Subpart S, Electrical __________
s. Subpart T, Commercial Diving __________
Operations.
t. Subpart Z, Toxic and Hazardous __________
Substances.
2. Review of Construction Standards and related hazard recognition.
a. Subpart C, General Safety and Health __________
Provisions.
A-2

OSHA Instruction TED 1.12A July 7, 1992 Office of Training and Education

b. Subpart D, Occupational Health and __________
Environmental Controls.
c. Subpart E, Personal Protective and __________
Life Saving Equipment.
d. Subpart F, Fire Protection and __________
Prevention.
e. Subpart G, Signs, Signals, and __________
Barricades.
f. Subpart H, Materials Handling, Storage,__________
Use, and Disposal.
g. Subpart I, Tools--Hand and Power. __________
h. Subpart J, Welding and Cutting. __________
i. Subpart K, Electrical. __________
j. Subpart L, Scaffolding. __________
k. Subpart M, Floors and Wall Openings. __________
l. Subpart N, Cranes, Derricks, Hoists, __________
Elevators, and Conveyors.
m. Subpart O, Motor Vehicles, Mechanized __________

Equipment, and Marine Operations.
n. Subpart P, Excavations. __________
o. Subpart Q, Concrete and Masonry __________
Construction.
p. Subpart R, Steel Erection. __________
q. Subpart S, Underground Construction, Caissons, Cofferdams and Compressed __________
Air.
r. Subpart T, Demolition. __________
s. Subpart U, Blasting and Use of __________
Explosives.
A-3

OSHA Instruction TED 1.12A July 7, 1992 Office of Training and Education

t. Subpart V, Power Transmission and __________
Distribution.
u. Subpart W, Rollover Protective __________

Structures; Overhead Protection.
v. Subpart X, Stairways and Ladders. __________
3. Maritime Standards. __________
4. Agricultural Standards. __________
5. Field Operations Manual. __________
6. Directives system overview. __________
7. IMIS Forms Manual. __________
8. OSHA Technical Manual. __________
9. Other Regulations and Procedures.
a. 1903, Inspections, Citations and __________
Proposed Penalties.
b. 1904, Recordkeeping. __________
c. 1905, Variances. __________
d. 1908, Consultation. __________
e. 1913, Access to Records. __________
f. 1960, Federal Employee OSH Programs. __________
10. SAVE's Manuals.
a. Regulatory and General Industry. __________
b. Construction. __________
c. Maritime. __________
11. OSHA Computerized Information System __________
(OCIS).
A-4

OSHA Instruction TED 1.12A July 7, 1992 Office of Training and Education

12. Instruments.
Both industrial hygiene and safety compliance officers should be familiar with instruments used by the other discipline.
A list of instruments with which CSHO's should be familiar may be developed by the Area Office. This list should be consistent with the list developed by the OSHA Technical Equipment Committee.

A-5

OSHA Instruction TED 1.12A July 7, 1992 Office of Training and Education

Appendix B
Resource Materials for Self-Study Assignments

The following is a list of sources that may be used in self-study segments related to the OSH Act, hazard recognition, standards, and industrial processes. This list is not intended to be all inclusive and the use of additional sources is encouraged.

A. Materials Developed by OSHA.

o "Eye Injuries and Eye Protection Equipment." 1985. Slides, audiocassette, and script.
o "Highlights of OSHA's Hazard Communication Standard (HCS)." 1989. Slides, script, handouts, and booklet.
o "Industrial Ventilation - A Practical Overview." 1991. Instructor guide and VHS videocassette.
o "Introduction to Industrial Hygiene for Safety Officers." 1985. Instructor guide, slides, student handouts, and overhead transparency masters.
o "Safety and Health Factors for Working with Formaldehyde (Revised)." 1988. Slides, audiocassette, and script.
o "Safety and Health Factors for working with Silica." 1990. Instructor guide, VHS videocassette.
o "Safety and Health Factors in Slips and Falls (Revised)." 1988. Slides, audiocassette, and script.
o "Safety and Health Factors in Spray Application Operations." 1985. Slides, audiocassette, and script.
o "Safety and Health Factors in Welding and Cutting." 1990. VHS videocassette.
o "Safety and Health Factors with Temperature Stress." 1985. Slides, audiocassette, and script.
o "Safety and Health Hazards in the Office." 1990. Instructor's guide, student manual, handouts, and slides.

B-1

OSHA Instruction TED 1.12A July 7, 1992 Office of Training and Education

o "Safety and Health Requirements for Working in Confined Spaces." 1985. Slides, audiocassette, and script.
o "Safety and Health Requirements for Working with Carbon Monoxide." 1990. Instructor guide and VHS videocassette.
o "Safety Hazard Recognition for Industrial Hygienists." 1985. Instructor Guide, slides, student handouts, and overhead transparency masters.
o "Trenching and Excavation Operations." 1988. Slides, audiocassette, and script.

B. Materials Available Through the Resource Center Audiovisual Material Circulation Project.

o Audiovisual programs covering construction operations and other topics are available to eligible borrowers, including Federal and State OSHA offices, through the Resource Center Audiovisual Material Circulation Project. For further information on this lending program, contact the Librarian, Office of Training and Education.

C. Materials Developed by Other Sources.

o American Industrial Hygiene Association. "Hygienic Guides." Akron, Ohio: American Industrial Hygiene Association, 1981.
o National Safety Council. Accident Prevention Manual for Industrial Operations. 2 vols. Chicago, Illinois: National Safety Council, 1988.
o National Safety Council. "Industrial Safety Data Sheets." 4 vols. Chicago, Illinois: National Safety Council.
o Olishifski, Julian B. ed. Fundamentals of Industrial Hygiene. 3rd ed. Chicago, Illinois: National Safety Council, 1988.
B-2


Archive Notice - OSHA Archive

NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.