Training for safety specialists

Under 1960.56(a), training must prepare specialists to perform technical monitoring, consulting, testing, inspecting, designing, and other tasks related to program development and implementation. It must also cover hazard recognition, evaluation and control; equipment and facility design; standards; analysis of accident, injury, and illness data; and related tasks.

• Training may combine courses, laboratory experiences, field study, and other formal learning experiences as described in 1960.56(a).
• Use this list as a checklist when designing a curriculum for a safety specialist: technical monitoring, inspections, hazard recognition, controls, design review, standards interpretation, and data analysis.

Cited authority: 1960.56(a).

Yes. Under 1960.56(b), each agency must implement career development programs for occupational safety and health specialists to enable staff to meet the agency’s present and future program needs.

• Career development programs should identify required skills now and anticipate future needs, then provide training, mentoring, and advancement paths to close gaps.
• Programs can include formal coursework, on-the-job training, rotations, certifications, and succession planning that align with agency mission requirements.

Cited authority: 1960.56(b).

Training must include a mix of learning methods; 1960.56(a) specifically calls for courses, laboratory experiences, field study, and other formal learning experiences to prepare specialists for technical tasks.

• Classroom courses alone are not sufficient if they do not provide the practical skills listed in 1960.56(a).
• Include hands-on lab work, field monitoring, and supervised inspections so specialists can practice sampling, measuring, and design review techniques.

Cited authority: 1960.56(a).

Under 1960.56(a), the training requirement specifically applies to occupational safety and health specialists to prepare them for technical monitoring and related tasks. Agencies should ensure that personnel who perform those specialist duties receive the described training.

• Staff who support specialists (e.g., technicians, inspectors) should receive appropriate training proportional to their duties, but the standard’s primary duty falls on specialists.
• Where other standards require training for broader employee groups (for example, asbestos awareness or bloodborne pathogens), agencies must also meet those separate requirements in addition to 1960.56 training for specialists.

Cited authority: 1960.56(a).

While 1960.56(a) and (b) require agencies to provide training and implement career development programs, they do not prescribe specific documentation formats; agencies should document training and career development so they can show programs meet present and future needs.

• Recommended documentation includes training plans, course completions, competency assessments, certifications, and career path records.
• Documentation helps demonstrate compliance with 1960.56(b) and supports workforce planning.

Cited authority: 1960.56(a) and (b).

Yes, an agency can use contractor-provided training for its safety specialists as long as the training prepares those specialists to perform the tasks listed in 1960.56(a). The agency should verify the contractor’s curriculum, instructor qualifications, hands-on elements, and competency assessments.

• Require course outlines, instructor credentials, practical exercises, and post-training evaluations to confirm learning objectives were met.
• Ensure contractor content addresses agency-specific hazards and regulatory requirements so specialists can apply training to agency programs.

Cited authority: 1960.56(a).

Yes. Under 1960.56(b), career development programs must enable specialists to meet present and future program needs, which includes updating skills for new sampling and analytical methods when appropriate.

• OSHA’s letter on hexavalent chromium sampling shows that agencies may adopt newer methods provided they meet performance requirements; career development should train specialists to evaluate and implement such methods (see OSHA’s response at https://www.osha.gov/laws-regs/standardinterpretations/2019-04-19).
• Use career development to cover method validation, quality assurance, and how to compare new methods to existing compliance criteria.

Cited authority: 1960.56(b) and OSHA letter on hexavalent chromium sampling methods (https://www.osha.gov/laws-regs/standardinterpretations/2019-04-19).

Yes. If specialists have responsibilities related to emergency response planning or oversight, 1960.56(a) requires training that prepares them for those specific technical tasks, which may include HAZWOPER topics.

• OSHA’s HAZWOPER interpretation explains emergency responder requirements and planning; include those elements in specialist training when the agency’s program requires it (see https://www.osha.gov/laws-regs/standardinterpretations/2010-02-22).
• Ensure specialists receive appropriate levels of responder training and understand planning, decontamination, and supervision obligations when applicable.

Cited authority: 1960.56(a) and OSHA HAZWOPER interpretation (https://www.osha.gov/laws-regs/standardinterpretations/2010-02-22).

Yes. Under 1960.56(a), agencies must train specialists in equipment and facility design and hazard recognition, which includes evaluating HVAC-related risks like oxygen-deficient atmospheres when those hazards are relevant to the workplace.

• OSHA’s interpretation about oxygen-deficient atmospheres clarifies how such hazards are treated for civilian employees and may inform specialist training content (see https://www.osha.gov/laws-regs/standardinterpretations/2024-07-16).
• Specialists should learn to assess oxygen levels, identify potential refrigerant release scenarios, and know when to consult respiratory protection guidance or other standards.

Cited authority: 1960.56(a) and OSHA letter on oxygen-deficient atmospheres (https://www.osha.gov/laws-regs/standardinterpretations/2024-07-16).

Agencies should incorporate relevant OSHA letters of interpretation into training because those letters clarify how OSHA applies standards in specific situations and can provide practical guidance for specialists, consistent with the training goals in 1960.56(a).

• Use letters of interpretation (for example, on sampling methods or emergency response) as case studies or reference materials to illustrate regulatory application and decision-making (see the hexavalent chromium letter at https://www.osha.gov/laws-regs/standardinterpretations/2019-04-19 and the HAZWOPER letter at https://www.osha.gov/laws-regs/standardinterpretations/2010-02-22).
• Train specialists to recognize when an interpretation applies to agency operations and when to seek further legal or program advice.

Cited authority: 1960.56(a) and OSHA interpretation examples (https://www.osha.gov/laws-regs/standardinterpretations/2019-04-19; https://www.osha.gov/laws-regs/standardinterpretations/2010-02-22).

Yes. Under 1960.56(a), specialists must be trained for tasks including hazard recognition and standards analysis, so training should include applicable health standards (for example, asbestos awareness or bloodborne pathogens) when those hazards are present in the agency’s workplaces.

• OSHA’s asbestos interpretation explains when custodial staff must receive awareness training; specialists should understand those triggers and training elements (see https://www.osha.gov/laws-regs/standardinterpretations/2006-01-17-0).
• For bloodborne pathogens, specialists who support exposure control planning should be familiar with the Bloodborne Pathogens standard and related enforcement guidance such as the HBV vaccination policy referenced in OSHA correspondence (see https://www.osha.gov/laws-regs/standardinterpretations/2000-11-01).

Cited authority: 1960.56(a), asbestos interpretation (https://www.osha.gov/laws-regs/standardinterpretations/2006-01-17-0), and HBV vaccination interpretation (https://www.osha.gov/laws-regs/standardinterpretations/2000-11-01).

Agencies must train specialists in standards analysis and hazard recognition under 1960.56(a), which includes understanding lockout/tagout definitions such as "authorized employee." Training should teach specialists the regulatory definitions and when exceptions apply.

• OSHA’s lockout/tagout interpretation clarifies that "authorized employee" refers to the definition in 29 CFR 1910.147(b) and explains exceptions for cord-and-plug equipment; include such interpretation material to explain real-world application (see https://www.osha.gov/laws-regs/standardinterpretations/2012-04-03).
• Train specialists to distinguish when an activity is excepted from the standard and when other agency safety requirements still apply.

Cited authority: 1960.56(a) and lockout/tagout interpretation (https://www.osha.gov/laws-regs/standardinterpretations/2012-04-03).

Yes. Specialists responsible for program development and implementation should be trained on OSHA recordkeeping and employee involvement requirements because 1960.56(a) requires training in standards and program implementation.

• OSHA’s recordkeeping enforcement guidance explains expectations for procedures and employee reporting protections; include those procedures in specialist training when they support agency recordkeeping programs (see https://www.osha.gov/laws-regs/standardinterpretations/2016-11-10).
• Specialists should learn how to implement reasonable reporting procedures, protect against retaliation, and maintain required records.

Cited authority: 1960.56(a) and OSHA recordkeeping interpretation (https://www.osha.gov/laws-regs/standardinterpretations/2016-11-10).

Under 1960.56(b), agencies must implement career development programs so staff can meet future needs, which includes updating skills for new technologies or standards changes.

• Use periodic refresher training, vendor briefings, standards updates, and hands-on conversion training where equipment or methods change — similar to how OSHA updated its view on audiometer earphones (see OSHA’s hearing conservation guidance at https://www.osha.gov/laws-regs/standardinterpretations/2013-03-11-0).
• Track new consensus standards and interpretations, and incorporate validation or side-by-side testing where needed to preserve data comparability.

Cited authority: 1960.56(b) and OSHA hearing conservation interpretation (https://www.osha.gov/laws-regs/standardinterpretations/2013-03-11-0).

Under 1960.56(a), specialists must be prepared to perform technical tasks; when they become trainers, the agency should ensure they are competent in both subject matter and teaching methods and that course content meets the listed training objectives.

• Verify trainers’ technical qualifications, hands-on experience, and ability to assess trainee competency.
• Ensure course materials reflect current standards, relevant OSHA letters of interpretation where applicable, and include practical exercises to demonstrate competence.

Cited authority: 1960.56(a) and relevant OSHA interpretations used as training references (for example, https://www.osha.gov/laws-regs/standardinterpretations/2019-04-19).