Requirements for employers to train employees exist throughout U.S. OSHA standards. However, some employers and, apparently, some OSHA inspectors, are not aware that training must be conducted in a manner that the employee can understand.

OSHA’s general policy is that if an employee receives job instructions in a language other than English, training and information must also be conveyed in that language. Similarly, says OSHA, if the employee’s vocabulary is limited, the training must account for that limitation. Furthermore, if employees are not literate, telling them to read training materials will not satisfy the employer’s training obligation.

“As a general matter, employers are expected to realize that if they customarily need to communicate work instruction or other workplace information to employees at a certain vocabulary level or in a language other than English, they will also need to provide safety and health training to employees in the same manner,” says OSHA.

OSHA adds that its training provisions contain a variety of specific requirements to ensure that employees are comprehending instruction. For example, standards covering lockout/tagout, respiratory protection, and bloodborne pathogens each require that employers take measures to ascertain the level to which the employee has comprehended the safety provisions.

In its instructions to inspectors, OSHA states, “If a reasonable person would conclude that the employer had not conveyed the training to its employees in a manner they were capable of understanding, then the violation may be cited as serious.”