Is OSHA 10 training required in Washington State?

No. OSHA 10 training is designed to help employees recognize hazards and take some basic steps to protect themselves. However, Washington State requires specific, and often hands on training for many topics, including Fall Protection, Confined Space and Respiratory protection. OSHA 10 does not meet the training requirements of these topics.

How often must employers (you) provide WAC 296-809 compliant Confined Space training?

You must provide training at no cost to each employee involved in permit-required confined space activities. The training must be in a language and vocabulary they understand, so they acquire the understanding, knowledge and skills necessary to safely perform assigned duties.

You must provide training when you introduce new or revised procedures as necessary.

You must provide training to each affected employee before an employee is first assigned to confined space duties, or if there is a change in an employee's assigned duties.

You must also provide training when there is a permit-required confined space hazard for which the employee has not already been trained.

Retraining must occur when there are deviations from your procedures for permit-required confined space entry, or the employee’s knowledge or use of your procedures is inadequate.

BUT, Attendant and Rescuer training is ANNUAL, as required by WAC 296-809-50014.

Can there be a Non-Permit Confined Space in Washington?

Let’s let the law answer this question in WAC 296-809-099.

Non-permit confined space. You will find the requirements for a non-permit confined space in WAC 296-809-600 - Alternate Methods.

WAC 296-809-60002 gives us some more direction.

Make sure the following conditions are met if using Alternative Methods:

You may enter permit-required confined spaces without a permit using alternative methods when you have monitoring and inspection data that supports the following:

(a) You have eliminated all the hazards or

(b) You have eliminated all of the physical hazards, and continuous forced air ventilation controls the actual or potential hazardous atmosphere. You must also have monitoring data that demonstrates the use of continuous forced air ventilation will maintain the permit-required confined space for safe entry. In the event the ventilation system stops working, entrants can exit the space safely.

You must have written documentation for the entrants before each entry.

You have two options in Washington State:

• Permit Required Confined Spaces

• Alternate Method Confined Spaces

Does Fall Protection training have to be instructor-led?

Not necessarily, but according to WAC 296-880-10015 employers must make sure that before an employee is allowed to perform work requiring the use of fall protection that they can:

(a) Demonstrate an understanding of the training specified above, and

(b) Demonstrate the ability to use fall protection properly.

That typically involves hands-on training and an evaluation, which is generally instructor-led.

How do I know my subcontractors are bringing employees with the correct training?

A good clue is that each employee on site has training documentation that includes:

(a) Name of each employee

(b) Date(s) of training

(c) Subject(s) of the training, and

(d) Name or signature of the competent person who conducted the training, signature of the employer, or employers designee.

If they don’t have a signed certification, they probably don’t have the right training.