Training required by Occupational Safety and Health Administration standards must be presented in a manner that employees can understand.
OSHA says an employer must instruct its employees using both a language and vocabulary that the employees are able to understand.
For example, if an employee does not speak or comprehend English, instruction must be provided in a language the employee can understand.
Similarly, if the employee’s vocabulary is limited, the training must account for that limitation. If employee are not literate, telling them to read training materials will not satisfy the employer’s training obligation.
As a general matter, says OSHA, employers are expected to understand that if they customarily need to communicate work instructions or other workplace information to employees at a certain vocabulary level or in a language other than English, they will also need to provide health and safety training to employees in the same manner.
OSHA compliance safety and health officers are responsible for determining whether employees have been trained effectively.
CHSOs must determine whether the training meets the requirements and intent of the specific standard, considering the language of the standard and all the facts and circumstances of the particular workplace, says the memo.