Annual written tests in place of refresher training

NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.

May 2, 1994

C.K. Genge, CSP
Safety and Health Program Supervisor
Corning Incorporated
[Recipient address omitted]
Dear Mr. Genge:

Thank you for your letter of March 18, regarding the Occupational Safety and Health Administration's (OSHA) requirements for refresher training. Your specific question is whether passing a "properly designed test" can be used in lieu of annual refresher training.

In circumstances when the hazard and assigned duty remain the same, the use of a properly designed, annual written test may suffice to meet annual training requirements. A written test by itself may not be sufficient, however, for training that requires a demonstration of competency (e.g., donning an doffing of personal protective equipment that is infrequently used). The intent of training (including annual and refresher) is to provide employees with the knowledge and skills necessary to perform their job duties and responsibilities with minimal risk to their safety and health.

We hope this information is helpful.

Sincerely,
H. Berrien Zettler, Deputy Director
Directorate of Compliance Programs

[Requester letter reproduced on OSHA page; omitted here.]