GWO Memo for US - DBR October 2018

• 29 C.F.R. §1926.451 Scaffolds – General Requirements • 29 C.F.R. §1926.503 Fall Protection

• 29 C.F.R. §1926.602 Material Handling Equipment • 29 C.F.R. §1926.760 Steel Erection – Fall Protection • 29 C.F.R. §1926.1060 Stairways and Ladders • 29 C.F.R. §1926.1211 Confined Space – Rescue and Emergency Services • 29 C.F.R. §1926.1424 Cranes and Derricks – Work Area Control OSHA offers Outreach Training Programs for General Industry, the Construction Industry, Maritime, and Disaster Site Work. See OSHA O UTREACH T RAINING P ROGRAM FAQ S available at According to OSHA, participation in the OSHA Outreach Training Program is voluntary because OSHA Outreach Training Program training “ does not meet the [workplace-specific] training requirements contained in any OSHA standard.” OSHA D IRECTORATE OF T RAINING & E DUCATION , O UTREACH T RAINING P ROGRAM R EQUIREMENTS (Jan 2017) (“O UTREACH T RAINING P ROGRAM ”) available at Nevertheless, because OSHA Outreach Training Program training provides students with additional useful knowledge about workplace safety and health hazards, some states (Connecticut, Massachusetts, Missouri, Nevada, New Hampshire, New York, Rhode Island, and West Virginia) v and local jurisdictions have adopted laws that mandate employee participation in 10 Hour and/or 30 Hour OSHA Construction Industry Outreach Training Program training. vi See O UTREACH T RAINING P ROGRAM and 365 OSHA T RAINING : S TATES R EQUIRING OSHA 10 AND / OR 30 T RAINING (“S TATES T HAT R EQUIRE OSHA O UTREACH T RAINING ”) available at hour-training/. Moreover, some employers and unions require workers to have OSHA Construction Industry Outreach Training Program training in order to be permitted to work on job sites or to fulfill their own safety program training goals. III. GWO’s SAFETY STANDARDS CAN AID COMPLIANCE WITH OSHA TRAINING REQUIREMENTS GWO’s BST and BTT standards can be used to aid employers in their compliance with certain OSHA-mandated requirements for training employees who work in the wind power industry. The BST and BTT standards includes instruction on First Aid, Manual Handling, Fire Awareness, Working at Heights, Sea Survival, Electrical, Mechanical, and Hydraulic; components of each would be expected to address certain aspects of OSHA’s safety training requirements for employees who work in the wind power sector of the General, Construction, and Maritime Industries. vii, viii There are no requirements that the employers themselves must provide training that is required for compliance with OSHA Standards and, therefore, required training may be provided by qualified third-parties such as GWO’s CTPs. With the exception of its Authorized Outreach Training Program Trainers, OSHA does not approve, certify, or endorse individual trainers, nor training programs. According to OSHA, it is the responsibility of the employer to determine if a trainer meets minimum requirements and


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