"Documentation." Oddly enough, this is the very thing being harped upon by both OSHA and seminar vendors. Why, you are not qualified unless you have it documented - and our seminar will make you qualified, provide that documentation.
Forget about OSHA, think about answering the lawsuit when Mrs. Doe testifies that her husband had worked in residential electrical work for 20 years, and had never actually touched a 480 V switchgear before his boss got that big commercial account. "Oh, yes, Mrs. Doe, he signed in at a training session on this date, these topics were discussed, and the trainer signed off here that your husband demonstrated that he could perform those tasks safely." That's why they harp on documentation. Same rules apply when OSHA takes you before an administrative law judge.
If so, what of the REQUIRED OSHA 30 hr. courses?
OSHA doesn't require 30-hour courses, or even 10. Some states do. But it's not, as some folks think, "Competent Person" training, and nowhere does OSHA describe it as such. It's general safety training, which mandates only 30 minutes of electrical safety training. Not enough for an electrician or many other trades.
OSHA is setting itself up as the AHJ... Just what is 'safety training?' Would it be the same for everyone, without regard to trade, etc?
OSHA's definition of safety training is LESS restrictive than NFPA's (I'll be happy cite my sources). And, no, it's not the same for everyone, as OSHA and NFPA point out. It's specific to the construction and operation of the equipment, installations, and the task at hand, to recognize and avoid the hazards involved. And it doesn't have to take a whole day: sometimes a tailgate talk will cover it, depending on the employee's previous training.
Whomever has the license to do so is deemed to be 'competent.' If OSHA is maintaining that their authority pre-empts state licensing, we have an whole new issue to discuss.
No, they're not! You've never seen an electrician take shortcuts? Licensure is intended to protect the homeowner. The National Electrical Code, written by the National Fire Protection Assn., is intended to prevent fire. Worker safety only came into the picture recently, and not as part of the code. And licensure tests only recently, and only in some states, considered worker safety. How many questions on the licensure test have to do with safety? It's OSHA's job to protect the worker, sometimes from himself.
While [Nevada] requires forklift drivers to have a "license' (certificate they took a class), OSHA rules plainly state that such a license has no merit whatever. Oh, no, you need to be re-trained, re-certified on every different machine in the plant - and do it all over again if you change jobs.
Exactly where do OSHA regulations "plainly state" that? OSHA makes the employer responsible to ensure that fork lift operators are trained (possibly by a third party) and evaluated as to their competence, then authorized by the employer to operate the machine. Re-training is only required if the operator has had an accident or is hot-dogging, or if the machine or working conditions change. The standard specifically says, at 29 CFR 1910(l)(5) that re-training doesn't have to cover everything all over again. OSHA's basically saying that even if you have a license, your employer can't let you operate the machine if you're hot-dogging.
Why does any of this not make good safety sense?