Subpart H
The orientation must cover section 19 of the OSH Act, Executive Order 12196, the requirements of 29 CFR Part 1960, and the agency's safety and health program. The regulation is explicit that orientation should include those four items so top managers understand the legal basis, executive order responsibilities, the Part 1960 requirements, and how the agency's own program operates (1960.54).
Each federal agency is responsible for providing orientation and other learning experiences to its top management officials. The text of 1960.54 states "Each agency shall provide top management officials with orientation and other learning experiences…" which places the duty on the agency to arrange and deliver this training.
Yes — the orientation must enable top management officials to manage their agency's occupational safety and health programs. The regulation requires that training give managers the knowledge and skills needed to manage the program effectively (1960.54).
No — 1960.54 does not set a specific frequency for orientation or additional learning experiences. The rule requires agencies to provide orientation and other learning experiences but leaves timing and frequency to the agency to determine based on program needs and circumstances (1960.54).
Yes — agencies may integrate the required orientation topics into broader executive-level training so long as the required subjects (section 19 of the Act, Executive Order 12196, Part 1960 requirements, and the agency safety and health program) are actually covered and the training enables managers to manage the program. The regulation requires those topics to be included but does not limit the delivery method (1960.54).
Other learning experiences can include short workshops, seminars, tabletop exercises, briefings on incident investigations, site walkthroughs with safety staff, and targeted briefings on emerging hazards. The regulation uses the phrase "orientation and other learning experiences," which allows flexibility in methods as long as the topics required by 1960.54 are covered and the training meets the goal of enabling managers to manage the safety program.
Yes — training must include coverage of Section 19 of the OSH Act and Executive Order 12196. The regulation explicitly lists those two items among the orientation topics that agencies must provide to top management officials (1960.54).
Not for military personnel in their unique military functions — federal OSHA coverage does not apply to military personnel and uniquely military equipment and operations, so 1960.54's requirements apply to agency officials as applicable to civilian federal employees and agency programs. OSHA's interpretation explains that Executive Order 12196 and 29 CFR Part 1960 apply to federal agencies, but military personnel and uniquely military systems are excluded from OSHA coverage; civilian employees and contractor employees working on non-uniquely military systems remain covered (Oxygen-deficient atmospheres in HVAC and 1960.54).
No — 1960.54 requires each federal agency to provide orientation to its top management officials (agency leadership). Contractor company executives are not "agency" officials, but civilian contractor employees performing work under federal contracts can be subject to OSHA standards and should receive appropriate safety training from their employer. OSHA explains that civilian contractors performing work under federal contracts are covered by OSHA standards where OSHA jurisdiction applies (1960.54 and Oxygen-deficient atmospheres in HVAC).
The regulation does not prescribe specific documentation requirements for top management orientation, but agencies are expected to maintain appropriate records and evidence that training occurred to demonstrate compliance and effective program management. While 1960.54 sets the training requirement, good practice and other parts of Part 1960 support documenting program activities so agencies can show they fulfilled their responsibilities (1960).
No — orientation for top management does not replace employee-level, hazard-specific training required by other standards. 1960.54 is intended to prepare managers to manage the agency safety program; employees who perform specific tasks must still receive the training that applies to those hazards (for example, requirements discussed in the lockout/tagout interpretation and the 29 CFR 1910.147 framework). OSHA's lockout/tagout interpretation reinforces that employee-specific training and authorized-employee requirements remain applicable where the standard itself applies (1960.54 and Lockout/Tagout definitions clarification (Original URL: https://www.osha.gov/laws-regs/standardinterpretations/2012-04-03)).
Yes — top management orientation should include agency recordkeeping and reporting obligations because those duties are part of managing an effective safety and health program. While 1960.54 lists the core topics, records and reporting are central program elements in Part 1960 and OSHA has issued guidance on recordkeeping procedures that agencies should understand (1960.54 and Recordkeeping enforcement procedures (Original URL: https://www.osha.gov/laws-regs/standardinterpretations/2016-11-10)).
An agency may seek approval to apply an alternate standard where necessary, but it must request the Secretary of Labor's approval in accordance with 29 CFR 1960.17. OSHA's interpretation on hexavalent chromium notes that 1960.17 allows alternate standards with prior approval and that a request must include the required supporting information (1960.54 and Hexavalent chromium sampling methods (Original URL: https://www.osha.gov/laws-regs/standardinterpretations/2019-04-19)).
Top management orientation should cover the agency's safety policy and objectives, management and employee responsibilities, hazard identification and correction processes, training programs, recordkeeping/reporting, incident investigation and corrective action, and emergency preparedness. These elements flow from the requirement in 1960.54 that orientation enable managers to manage the agency safety and health program effectively.
Yes — agencies may use external trainers or consultants to deliver orientation, but the agency remains responsible for ensuring the training content meets the requirements of 1960.54 and that top managers are competent to manage the safety program after the training.
Agencies should ensure orientation covers the core subjects named in 1960.54 and is tailored to address differences across facilities; they can provide a central orientation plus facility-specific briefings for local conditions. The regulation requires coverage of the listed topics but allows agencies to adapt delivery to their organizational structure (1960.54).
Yes — agencies may use industry consensus standards to inform training on technical hazards, but reliance on such standards does not substitute for compliance with applicable OSHA requirements. OSHA has said it will sometimes refer to ANSI or other standards as evidence of recognized hazards or feasible abatement measures, but citations are based on OSHA standards or the federal-agency equivalent in Part 1960 (1960.54 and Adoption of ANSI window cleaning standard (Original URL: https://www.osha.gov/laws-regs/standardinterpretations/2005-03-28-0)).
Yes — orientation should explain where OSHA coverage applies and where it does not (for example, military-unique activities or state plan differences) so managers understand jurisdictional boundaries and obligations. OSHA's interpretations explain that federal OSHA coverage differs for military activities and that state plans implement comparable standards in their jurisdictions (1960.54 and Oxygen-deficient atmospheres in HVAC (Original URL: https://www.osha.gov/laws-regs/standardinterpretations/2024-07-16)).
Yes — since agencies may seek to apply alternate standards under 29 CFR 1960.17, orientation should cover the existence of that process and the need for Secretary of Labor approval before implementing any alternate standard. OSHA's hexavalent chromium interpretation discusses the alternate-standard process and the required approval steps (1960.54 and Hexavalent chromium sampling methods (Original URL: https://www.osha.gov/laws-regs/standardinterpretations/2019-04-19)).
Top management orientation should include awareness of employee protection obligations under specific OSHA standards (for example, management should know that employee first-aid responders with occupational exposure are covered by the Bloodborne Pathogens Standard and associated vaccination policies). OSHA's HBV interpretation explains employer obligations for hepatitis B vaccination and when limited exceptions may apply, and covering such obligations helps managers ensure program compliance (1960.54 and HBV vaccination for first aiders (Original URL: https://www.osha.gov/laws-regs/standardinterpretations/2000-11-01)).