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Previous by Date: Subject: Re: Fwd: [DCHAS-L] OSHA COVID-19 Tip of the Day for October 23, 2020 Date: Friday, October 23, 2020 at 6:57:43 PM Author: Jeffrey Lewin <jclewin**At_Symbol_Here**MTU.EDU> |
Next by Date: Subject: Re: Fwd: [DCHAS-L] OSHA COVID-19 Tip of the Day for October 23, 2020 Date: Sat, 24 Oct 2020 00:09:24 +0000 Author: Monona Rossol |
The same issue is present for hazardous waste training where the training is required by RWG but documentation of same was not required by the reg. We had much debate with inspectors and required them to show the regulation specifics which they couldn‰??t do. We did extensive training and did document but looked at inspections from a risk management approach. We informed all who took the training that they were responsible for knowing the 4 basic elements of the training and responding appropriately whenever questioned by inspectors. We informed inspectors that we provide training on the requirements and they could inquire of the individuals only on these 4 issues of required training. With the need to train over a thousand new people every year the probability of not having documentation was probably higher than the individuals in the lab not knowing the four elements of the requirement. Worked well and individual lab personnel had more ownership of the matter.
Larry
> On Oct 23, 2020, at 2:39 PM, Daniel Kuespert <0000057d3b6cd9b7-dmarc-request**At_Symbol_Here**lists.princeton.edu> wrote: ---
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>
> •ČŔThis is not to say that having proper documentation isn‰??t useful or good. It‰??s great as an admin control to make sure people get their training, and documents settle a lot of compliance arguments. Besides, DOT and EPA require training docs for specific trainings too, like AHERA qualifications. I don‰??t recall any general requirement to document everything in EPA, though‰??is there a specific example you had in mind?
>
> Regards, Dan
>
> Sent from my iPad
>
>> On Oct 23, 2020, at 17:06, Stuart, Ralph
>>
>> •ČŔ
>>>
>>> there was a court decision (OSHA v. Westvaco?) that held that OSHA cannot require any documentation not specifically asked for by a reg.
>>
>> So, while DOT and EPA regulations require safety training documentation (for specific hazmat related jobs), OSHA can't for general safety training? I've been working in compliance for 35 years and never picked up on that subtle point. I suppose OSHA's proposed regulations have a high paperwork reduction standard to cross...
>>
>> Thanks for the explanation.
>>
>> - Ralph
>>
>>
>> Ralph Stuart, CIH, CCHO
>> Environmental Safety Manager
>> Keene State College
>> 603 358-2859
>>
>> ralph.stuart**At_Symbol_Here**keene.edu
>>
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