Depending on the reason for an OSHA inquiry into your training plans, it may not be enough to just have a sign-in sheet for a meeting or seminar as proof of training.  For example, if the reason they are looking is just to ascertain if you have records or if you have completed a recurring required training, a sign-in sheet may be enough at that moment.  However, if the reason they are looking is the result of a suspected workplace injury or a complaint that training was inadequate, they are likely to want more information on the content of the training AND what steps the employer took to ensure it was understood.

At a minimum, in addition to the “sign in sheet,” it’s also important to maintain a written record of the content of the training/meeting to prove what was said or taught in the training.  Just keep this in mind: mere attendance as a meeting where a piece of information or training was discussed rarely ensure comprehension of the materials; lots of folks are at meetings and just days later can’t explain a single point that was discussed at that meeting.

That’s why we strongly suggest adopting some method to evaluate the staff member’s understanding of the training. 

In the past, OSHA has accepted performance demonstrations and written tests as evidence the staff member understood the training.  Performance evaluations are where the instructor or suitably knowledgeable person “watches, then signs off” that the staff member performed a required task properly.  This type of validation is common for topics such as the donning, use, and removal of PPE (like respirators) and for operating dangerous machinery.  In the veterinary hospital, that often means operation of the radiology machine, anesthesia machine, and similar medical devices.  There must be a written objective checklist that the evaluator uses for this method to be acceptable. 

The written test method is more widely used and suitable for many topics, including HAZCOM, fire prevention and response, etc.  We think it is essential for every training episode to include a short written “quiz” that every staff member must complete to be considered “trained” on that topic.  The staff member must score 100% on such a quiz (in other words, they can’t just understand “some” of the safety rules.)  If a staff member misses a question (or questions) on such a quiz, it is acceptable to coach them on the correct procedure, then allow THE STAFF MEMBER to change their answer on the test along with signing the change.  The instructor will then annotate on the quiz that the staff member was retrained on the correct procedure after the first answer and was allowed to change their answer because he/she demonstrated the correct solution to the instructor after further coaching.

As for issuing a certificate: I like them and I use them in my sessions.  I think the staff member looks at the training a little more seriously when the “earn a certificate” and OSHA compliance officers seem to like them, BUT they have limitations.  Like the sign-in sheets, they will often suffice as evidence that a person attended a specific meeting.  A completion certificate will only help prove understanding if there was an examination of the staff member’s competence AND written evidence to back it up.

Click here for more info and ideas on delivering safety training in a veterinary hospital.