Re-Thinking Train-the-Trainer



Quite often I will get a call in which the caller will want to know “what one class do they need to take to become a safety trainer”? Obviously, it takes experience and technical training to become a professional safety trainer; but the question is not really that far off when you start talking about train-the-trainer classes. In the spirit of full disclosure, I will tell you that I teach Train-the Trainer classes for a few OSHA Institutes and have done so for many years. In fact, I am a senior trainer for the largest provider of training in the world.  The requirements in the regulations as to who is “Qualified” to teach a certain type of class is clouded by OSHA not wanting to “Certify” anyone (in just about anything) and the lack of a liptis test  for the minimum requirements for teaching a safety course. I have included some of the excerpts from different OSHA regulations, letters of interpretations, and comments at the end of this article in order to give you a better understanding of the “concept” of qualified trainers. These references are common throughout OSHA and are used in the absence of a direct requirement on a specific subject.

What OSHA and other entities would like to see for “Qualifications” is experience in the field as well as technical training in how to deliver a course to adults, answer questions that may come up, and present the information in a way that increases knowledge, retention, application, develops higher thinking skills, and relevancy. What they get many times is experience; coupled with reading from a slide, only knowing what is written on a piece of paper, and no control over the classroom, students, or documentation. While each of these both meets the minimum requirements found in many train-the-trainer courses, I believe that we could all agree that none of us would like to be trained by that individual.

So what should be the requirements? Well it is obvious that experience should be a part of the formula. However, it would be unnecessary for the instructor to have a doctorate if they were only teaching awareness training (which is the level many safety classes are taught). If you look at the requirements for OSHA Outreach Trainers (this is trainers that can teach the OSHA 10 and 30 hour classes at an awareness level only) the requirement is five years of experience or a degree, CSP Certification   / experience combination. The prerequisite for the experience is presumably with a job description that avails the applicant duties that involve safety responsibility. You then have to take a general industry or construction course that in 26 hours covers basic principles, hazardous conditions, and safety respectively. Once you pass that class, you will then have to take another 26 hour class that places special emphasis on the topics covered in the 10 and 30 hours course as well as those subjects considered by OSHA to be more hazardous. Additionally, students are briefed (not my words but OSHA’s) on effective instructional approaches and the use of visual aids/handouts. You will not receive a certification because OSHA does not “certify” anyone but rather you will receive authorization to teach the 10 and 30 hour class only. For many trainers, this may be the pentacle of their “professional training experience”. But what about the other 50’ish specialty topics that require specialized training? For those wanting to train other topics in safety and health there are individualized courses on specific topics as well as train-the-trainer classes as well.

The training scenario normally plays out this way…. You want to teach confined space training. You would normally take an initial (awareness) course in confined space and then another train-the-trainer course normally titled Confined Space Train-The-Trainer. If you want to teach Lock Out, Tag Out (LOTO) then you would normally take an awareness class in LOTO and then another … you guessed it LOTO Train-the-Trainer class. The  problem is that while you could make the argument that the technical aspects between the awareness class (on any subject) and the same subject in the train-the-trainer class should be different or more in-depth; the teaching adults section of most trainer classes are almost identical.  Keep in mind that trainers who take the train-the-trainer class in whatever subject can still only teach those subjects to others at an awareness level. It is generally accepted that they cannot teach a train-the-trainer class in that subject because the level at which the train-the-trainer class was given originally only covered awareness training. Wow, that was really confusing. To make it simpler I will use a college rule of instruction. “You can only teach one level below the level you were trained”. In other words, teachers with a Masters degree can teach Associates and Bachelor degree programs; they cannot teach students striving for a Master degree. If you only have a Bachelors degree, you can only teach Associate Degree programs ect.

Enter the Competent and or Qualified Person Designation

OSHA and Industry saw that a lot of the training that was being given was at the awareness level but the requirements of the actual job required a higher degree of competency. With the requirement of “The Competent Person” (a job title…. not an appraisal of how well you do your job) OSHA defined  a competent person as

“…one who is capable of identifying existing and predictable hazards in the surroundings or working conditions which are unsanitary, hazardous, or dangerous to employees, and who has authorization to take prompt corrective measures to eliminate them” [29 CFR 1926.32(f)]. By way of training and/or experience, a competent person is knowledgeable of applicable standards, is capable of identifying workplace hazards relating to the specific operation, and has the authority to correct them. Some standards add additional specific requirements which must be met by the competent person.

Competent Person (CP) training is something relatively new in the safety profession and is not taught by many training entities. It is not because they aren’t big enough, but because they don’t have seasoned training personnel (back to our college rule) or they don’t want the responsibility of training to a standard above the awareness level. Competent Persons many times have the responsibility (and authority) normally afforded the owner of the company and can make decisions on the job. Currently, there are over 120 different references in the OSHA regulations requiring competent persons on the job every day.  Different from the competent person is the qualified person.

The qualified person according to OSHA:

…a qualified person must have a recognized degree, certificate, etc., or extensive experience and ability to solve the subject problems, at the worksite. This is the reason why 29 CFR 1926.651(f) requires that supporting systems design shall be by a qualified person. There may be a requirement for more technical or engineering knowledge here.

Qualified Person training is even more stringent than “awareness” and “competent person” training in that OSHA is looking for a formal training certificate in the specific subject area or [documented] extensive training (can be found in properly prepared training records) on the individual. In many OSHA regulations they may call for a “competent person qualified in……”. This means that they want a technically knowledgeable person who has authority to make decisions.

So back to our train-the-trainer class. You would be hard pressed to find a Train-the-Trainer Competent Person class in just about any subject. Not that they don’t exist but the time, experience of the instructor, and money, involved in a class such as this would be prohibitive for many organizations.

At the National Center for EHS Education (NCEHSE) we offer classes that meet those requirements in a unique and different way. While we do offer awareness classes (like 90% of the other schools), we also offer Competent Person designation classes as well. Our train-the-trainer class operates a little differently because we have broken down the actual OSHA requirement to their essential components: (1) a subject technical class or experience and (2) specialized training in adult education. Being able to convey the training message is very important to OSHA.  At NCEHSE you can take one or both of the two “Training the Professional Trainer classes”.

  • Class #1 (NC-2240a) Training the Professional Trainerdeals with training adults, managing classrooms, goals and objectives, developing higher thinking skills, and integrating technology, multi-media, and presentation skills (needless to say this is much more than a “briefing”). This class is perfect for most trainers in the field using or modifying provided materials. Upon successful completion of the class, you couple your documented experience or other specific subject technical knowledge in meeting the requirements for training (one level below) your experience and technical training.


  • Class #2 (NC-2240b) Developing Qualified and Competent Worker Training goes beyond delivery and presentation into building quality classes that meet ANSI design requirements, and technically specific materials for a more qualified worker. In this class you are actually developing a class for a specific topic at a specific training level. Training managers, curriculum developers, and higher level instructors need this class to quantify and validate their training credential requirements.


So is this the future of professional training? …I hope so. Training from NCEHSE is different from other sources only because it is being driven by industry standards and is pro-active in design and delivery. NCEHSE is a part of the State University system and has to meet criteria for design, delivery, and content in order to maintain its accreditation. This is why many classes offered through NCEHSE can be applied to a degree or four different certifications,

So that is the long and short of Train-the-Trainer classes and the actual requirements. Why aren’t other entities training the way NCEHSE does? Eventually they will. Safety training in America is still in its growing stages. It is not that others can’t do it better or different, it is just that the model for safety training was built years ago using designs from agriculture and industrial training stemming from the mid 1900’s. The old system does work, IMOP it just needs to be more efficient and effective for 21st. century workers and managers.

Below are excerpts from different OSHA “Trainer Qualifications” questions. These are listed not as a verbatim reference but rather as an indicator of the thought process for trainer qualification.

OSHA Outreach Trainer Requirements

You must meet separate prerequisites for experience and training. You may not substitute one prerequisite to fulfill the other prerequisite. OSHA does not issue waivers for either the experience or training prerequisites. The prerequisites are as follows:

  1. Have five years of general industry safety experience. A college degree in occupational safety and health, a Certified Safety Professional (CSP), or Certified Industrial Hygienist (CIH) designation may be substituted for two years of experience. Obtain guidance on whether you meet this requirement from theOSHA Training Institute (OTI) Education Centerwhere you want to take the training.
  2. Complete OSHA course #511, Occupational Safety and Health Standards for General Industry. This course covers OSHA policies, procedures, and standards, as well as general industry safety and health principles.

If you have fulfilled the prerequisites, you must complete OSHA course #501, Trainer Course in OSHA Standards for General Industry. Special emphasis is placed on those topics that are required in the 10- and 30-hour programs as well as those that are the most hazardous. Course participants are briefed on effective instructional approaches and the effective use of visual aids and handouts. Persons successfully completing this course will receive an “Authorized General Industry Trainer Card”.

The “Hazardous Waste Operations and Emergency Response” standard (HAZWOPER), 29 CFR 1910.120, states in paragraph (e)(5) that “Trainers shall be qualified to instruct employees about the subject matter that is being presented in training”. In addition, 29 CFR 1910.120(e)(5) explains that the qualifications of the instructors may be shown by academic degrees, completed training courses and/or work experience.

At this time, OSHA does not have any specific requirements to certify an instructor. …The trainer must be able to demonstrate an understanding of the material to be transmitted to employees.

Paragraph 1910.120(q)(7) states that trainers “shall have satisfactorily completed a training course for teaching the subjects they are expected to teach, such as courses offered by the U.S. Fire Academy, or they shall have the training and/or academic credentials and instructional experience necessary to demonstrate competent instruction skills and a good command of the subject matter in the specific subject they are to teach.”

Would the normal safety training given to employees in industry or manufacturing be considered as experience for a HAZWOPER or HAZMAT instructor? Answer: This may satisfy some of the training requirements, although the instructor will probably need additional, more thorough, training to convey the information to employees.

…the standard identifies qualified trainers as those who have satisfactorily completed an instructional program or who otherwise have the academic credentials and instructional experience necessary to teach a HAZWOPER training program. In other words, a trainer must be able to demonstrate proficiency and understanding of the material to be transmitted to trainees and have some credentials or experience in training others. We also note that trainers must continue to attend training in order to maintain their knowledge and skills base.

Michael O’Berry is the Director of the National Center for EHS Education (NCEHSE)


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