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OSHA 1960.57

Inspector training requirements

Subpart H

14 Questions & Answers
10 Interpretations

Questions & Answers

Under 1960.57, what topics must safety and health inspectors be trained on?

Yes — safety and health inspectors must be trained on the standards, equipment, testing procedures, hazard evaluation, abatement suggestions, and report preparation required to carry out inspections. See the training content described in 1960.57.

  • Inspectors need training in the appropriate OSHA and agency standards they will apply during inspections.
  • They must know how to use and interpret appropriate monitoring and testing equipment and procedures to identify and evaluate hazards.
  • Training must cover suggesting general abatement measures and preparing inspection reports and documentation that support inspection findings.

Under 1960.57, who must an agency provide inspector training to?

Agencies must provide training to their safety and health inspectors. 1960.57 explicitly requires each agency to provide the training needed for inspectors to identify and evaluate hazards and prepare reports.

  • This applies to agency employees who perform assigned inspections as part of the federal safety and health program.
  • If civilian contractor employees perform inspections on behalf of the agency and fall under OSHA coverage, the agency should ensure comparable training (see related jurisdiction guidance in the oxygen-deficient atmospheres interpretation at https://www.osha.gov/laws-regs/standardinterpretations/2024-07-16).

Under 1960.57, does inspector training have to include instruction on the use of sampling and testing equipment and methods?

Yes — training must include the use of appropriate equipment and testing procedures necessary to identify and evaluate hazards. 1960.57 requires training on equipment and procedures.

  • For complex sampling (for example, hexavalent chromium), employers/inspectors must use monitoring and analytical methods that meet performance requirements; OSHA has confirmed that acceptable methods are allowed provided they meet accuracy and confidence criteria (see the hexavalent chromium interpretation at https://www.osha.gov/laws-regs/standardinterpretations/2019-04-19).
  • Training should cover selection, calibration, operation, limitations, and interpretation of sampling results so inspectors can evaluate compliance and recommend abatement.

Under 1960.57, are inspectors required to be trained in preparing inspection reports and documentation?

Yes — inspectors must be trained in report preparation and documentation to support inspection findings. 1960.57 specifically includes preparation of reports and other documentation as part of required training.

  • Training should cover what evidence to collect, how to document measurements and observations, and how to write findings that clearly support abatement recommendations.
  • Proper documentation supports enforcement, corrective action planning, and recordkeeping requirements.

Under 1960.57, must inspector training include how to identify hazards and suggest general abatement procedures?

Yes — training must teach inspectors how to identify hazards and suggest general abatement measures during or after inspections. 1960.57 requires training in hazard identification, evaluation, and suggesting general abatement procedures.

  • ‘‘General abatement procedures’’ means practical, feasible ways to reduce or eliminate recognized hazards (engineering controls, safe work practices, PPE, administrative controls).
  • Inspectors should be trained to distinguish immediate dangers requiring urgent action from hazards that need scheduled abatement.

Under 1960.57, does OSHA coverage apply to military facilities and therefore affect inspector training needs?

Not always — OSHA coverage does not apply to military personnel and uniquely military equipment and operations, but civilian employees in comparable operations are covered and require compliance and training. The OSHA interpretation on oxygen-deficient atmospheres explains that military personnel and uniquely military systems are excluded from OSHA coverage under Executive Order 12196, while civilian employees and contractor personnel working on non-unique systems remain covered (see https://www.osha.gov/laws-regs/standardinterpretations/2024-07-16). Agencies must ensure inspectors who cover OSHA-covered civilian workplaces receive the training required by 1960.57.

  • If inspections involve civilian employees or contractor work that is not uniquely military, inspector training should cover applicable OSHA standards and hazards.
  • For situations involving both military-unique and civilian-covered operations, inspector training should include how to recognize the jurisdictional distinctions referenced in the OSHA interpretation.

Under 1960.57, can an agency adopt alternate sampling or training methods, and what approvals might be needed?

Yes — agencies may use alternate methods if they meet the performance requirements and, where an alternate standard is to be applied agency-wide, the agency must request prior approval as required elsewhere in Part 1960. 1960.57 requires inspectors be trained in appropriate procedures, and OSHA has explained in the hexavalent chromium letter that performance-based monitoring methods are acceptable if they meet the accuracy requirements (see https://www.osha.gov/laws-regs/standardinterpretations/2019-04-19). The same letter also notes that an agency seeking to implement an ‘‘alternate standard’’ under 29 CFR 1960.17 must request Secretary of Labor approval before implementing it.

  • For sampling/analysis: use methods that meet the accuracy and confidence criteria described in applicable OSHA standards or acceptable interpretations.
  • For adopting alternate agency standards: follow the procedures and request approval per 29 CFR 1960.17 (as discussed in the 2019 interpretation).

Under 1960.57, do inspectors who may enter oxygen-deficient spaces need special training or procedures?

Yes — inspectors who may encounter oxygen-deficient atmospheres must be trained and follow appropriate respiratory and entry procedures for those hazards. 1960.57 requires training on appropriate standards and testing procedures, and OSHA's oxygen-deficient atmospheres interpretation explains that when OSHA standards apply to civilians, oxygen-deficient atmospheres are considered immediately dangerous to life and health (IDLH) under 29 CFR 1910.134 (see https://www.osha.gov/laws-regs/standardinterpretations/2024-07-16).

  • Training should include atmospheric testing, recognizing IDLH conditions, use of proper respirators or supplied-air systems, and confined-space entry procedures where applicable.
  • If inspectors could encounter oxygen-deficient conditions, the agency should ensure competency in relevant standards and emergency response procedures before entry.

Under 1960.57, how often must agencies retrain safety and health inspectors?

1960.57 does not specify a mandatory retraining interval; agencies must establish and provide the appropriate training, including refresher training as needed to maintain inspector competency. 1960.57 requires agencies to provide the training necessary for inspectors but leaves scheduling and frequency to the agency's judgment based on the complexity of hazards and tasks.

  • Agencies should set retraining intervals based on factors such as changes in standards, introduction of new equipment or procedures, observed inspector performance gaps, or when new hazards arise.
  • For topic-specific programs, other OSHA standards may prescribe frequency (for example, asbestos awareness is annual under 29 CFR 1910.1001(j)(7)(iv); see OSHA’s asbestos interpretation at https://www.osha.gov/laws-regs/standardinterpretations/2006-01-17-0).

Under 1960.57, must agencies document and retain records of inspector training?

Yes — agencies should document inspector training and retain records as part of a complete safety and health program, even though 1960.57 itself focuses on providing training rather than detailed recordkeeping rules. 1960.57 requires agencies to provide training; other OSHA guidance and recordkeeping provisions recommend documenting training to demonstrate compliance.

  • Training records should include who was trained, topics covered, dates, instructor qualifications, and any testing or competency verification.
  • Documented training supports program oversight, inspector qualification, and defense of inspection findings; see principles in OSHA recordkeeping guidance (e.g., the 29 CFR 1904.35 enforcement memorandum at https://www.osha.gov/laws-regs/standardinterpretations/2016-11-10 for recordkeeping/employee involvement policy context).

Under 1960.57, do contractor or private-sector personnel who inspect federal worksites need the same training as agency inspectors?

If contractor or private-sector personnel perform inspections on federal worksites that are covered by OSHA, they need training equivalent to that required for agency inspectors to ensure they can identify hazards and prepare supportable documentation. 1960.57 requires agencies to provide training for safety and health inspectors; OSHA’s coverage interpretation clarifies that civilian contractor employees are often covered by OSHA standards (see https://www.osha.gov/laws-regs/standardinterpretations/2024-07-16).

  • The agency should ensure contractors have documented training and competency for the specific standards, equipment, and testing methods applicable to the inspections they perform.
  • Where contractors are responsible for monitoring (e.g., chemical sampling), the methods must meet OSHA performance requirements (see the hexavalent chromium interpretation at https://www.osha.gov/laws-regs/standardinterpretations/2019-04-19).

Under 1960.57, what technical accuracy is expected of inspectors who perform sampling for contaminants like hexavalent chromium?

Inspectors and employers must use monitoring and analysis methods that meet the accuracy and statistical confidence requirements of the applicable OSHA standard; for hexavalent chromium OSHA requires methods that measure to within ±25% accuracy and 95% confidence at or above the action level, as explained in the 2019 interpretation (https://www.osha.gov/laws-regs/standardinterpretations/2019-04-19). 1960.57 requires training in the appropriate testing procedures so inspectors understand and can apply those performance criteria.

  • Training should cover method selection, calibration, quality control, limits of detection, and how to compare results to OSHA PELs or action levels.
  • If an alternate inhalable sampling method is used, it must meet the performance criteria described in the OSHA interpretation to be acceptable for compliance determinations.

Under 1960.57, should inspectors be trained in asbestos awareness when inspecting custodial or housekeeping operations?

Yes — inspectors who inspect custodial or housekeeping operations in facilities where asbestos-containing material (ACM) or presumed ACM may be present should be trained in asbestos awareness. 1960.57 requires training in appropriate standards and procedures, and OSHA’s asbestos awareness interpretation explains that custodial employees must receive awareness training and that inspectors dealing with those workplaces should understand those requirements (see https://www.osha.gov/laws-regs/standardinterpretations/2006-01-17-0).

  • Asbestos awareness training should cover health effects, recognizing damaged ACM/PACM, proper response to fiber release episodes, and housekeeping requirements.
  • Inspectors should be able to identify when specialized asbestos controls, testing, or work practices are required and refer to the applicable asbestos standards.

Under 1960.57, do inspectors need training on lockout/tagout concepts and the limits of standard exceptions (e.g., cord-and-plug equipment)?

Yes — inspectors must be trained on lockout/tagout requirements and on recognizing when exceptions apply or when additional protections are needed. 1960.57 requires training in appropriate standards and procedures; OSHA’s lockout/tagout interpretation clarifies that certain exceptions (like cord-and-plug equipment) remove the full application of 29 CFR 1910.147 only when the exception’s criteria are met and that exclusion from one standard does not relieve the agency from other safety obligations (see https://www.osha.gov/laws-regs/standardinterpretations/2012-04-03).

  • Training should cover the definition of ‘‘authorized employee,’’ when the cord-and-plug exception applies, and when full LOTO procedures are required.
  • Inspectors must also know that even if a task is excepted from 1910.147, agencies still must comply with agency safety duties (e.g., 29 CFR 1960.8) to protect employees.