In response to the demand for a recognizable basic safety training standard in the wind turbine industry, GWO published the first version of its “BST” (basic safety training) in 2012. The GWO BST describes the requirements for the basic safety training courses that are recommended by GWO members and ensures that the work of any GWO BST-Certified Training Provider (“CTP”) is competent and proficient. To obtain GWO certification, CTPs are subject to an in-depth audit process performed by certification bodies that have been accredited to ISO 9001 and OHSAS 18001 standards and that must follow the rules for accreditation in ISO 17021:2001 when offering certification services for CTPs. Any person that is granted a GWO BST certificate from a CTP is considered competent and knowledgeable within the field of basic safety in the wind power industry. GWO members accept any person that holds a GWO BST certificate as someone that possesses the required knowledge to stop an unsafe work situation. GWO works with its membership and the wind power industry supply chain, sharing industry statistics and risk evaluations, in order to identify training objectives. In some cases the training objectives are subsequently developed into new GWO standards. For example, the GWO Basic Technical Training Standard (“BTT”) and the GWO Basic Safety Training Refresher Standard (“BTSR”) are two of GWO’s training objectives that were developed into new standards. II. OSHA REQUIREMENTS FOR EMPLOYEE TRAINING The U.S. Occupational Safety and Health Act of 1970 (“OS&H Act”) mandates that employers must comply with safety and health standards and regulations promulgated by the Occupational Safety and Health Administration (“OSHA”), or by a state with an OSHA- approved state plan. i See 29 U.S.C. §651 et seq . In addition, the OS&H Act’s General Duty Clause, Section 5(a)(1), requires employers to provide their employees with a workplace that is free from recognized hazards likely to cause death or serious physical harm. See id . To this end, the OS&H Act and the regulations promulgated thereunder impose multiple duties upon employers ii and provide employees with many rights, including the right to receive clear training and information (in layman's terms and in a language that employees understand) about the hazards of their workplace, ways to avoid harm, and applicable OSHA standards and laws. See e.g ., W ORKPLACE S AFETY : OSHA AND OSH A CT O VERVIEW available at https://employment.findlaw.com/workplace-safety/workplace-safety-osha-and-osh-act- overview.html. There are more than 100 OSHA standards that contain “explicit safety and health training requirements to ensure that workers have the required skills and knowledge to safely do their work.” O CCUPATIONAL S AFETY AND H EALTH A DMINISTRATION , T RAINING R EQUIREMENTS IN OSHA S TANDARDS (OSHA 2254-09R 2015) (“T RAINING R EQUIREMENTS IN OSHA S TANDARDS ”) available at https://www.osha.gov/Publications/osha2254.pdf and O CCUPATIONAL S AFETY AND H EALTH A DMINISTRATION , R ESOURCE FOR D EVELOPMENT AND D ELIVERY OF T RAINING TO W ORKERS (OSHA 3824-08 2015) available at
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