Standard Interpretations - Table of Contents
• Standard Number: 1910.1030; 1910.1030(g)(2)(v)

January 24, 2007

Mr. D. C. Skinner
Employer Management Technical Policy Consultant
Ohio Bureau of Workers' Compensation
One Government Center, Suite 1236
Toledo, Ohio 43604

Dear Mr. Skinner:

Thank you for your letter to the Occupational Safety and Health Administration's (OSHA's) Directorate of Enforcement Programs (DEP). This letter constitutes OSHA's interpretation only of the requirements discussed and may not be applicable to any question not delineated within your original correspondence. You requested clarification on OSHA's interpretation of acceptable time lapse for "annual" training.

Scenario: Various OSHA standards address frequency of employee training. Some standards are very explicit on frequency, stating "no later than 12 months from the date of the previous training," while others simply state that training must be performed "at least annually."

Question: Could you please clarify OSHA's interpretation of training requirements and what is expected when training must be conducted "at least annually"?

Reply: You are correct in stating that the language may vary in certain OSHA standards. However, wherever OSHA standards require that employee training be conducted "at least annually," OSHA interprets that to mean that employees must be provided re-training at least once every 12 months (i.e., within a time period not exceeding 365 days.) This annual training need not be performed on the exact anniversary date of the preceding training, but should be provided on a date reasonably close to the anniversary date taking into consideration the company's and the employees' convenience in scheduling. If the annual training cannot be completed by the anniversary date, the employer should maintain a record indicating why the training has been delayed and when the training will be provided.

Please keep in mind that the term