OSHA Language Requirements: What you need to know to stay compliant

Preventing workplace injuries and fatalities is critical to your business’ success from both ethical and financial viewpoints. However, with thousands of safety standards in place, it can be challenging for employers to know, understand, and abide by the Occupational Safety and Health Administration’s (OSHA) regulations and guidelines. So where should you focus your compliance efforts?

We recommend starting with OSHA’s Hazard Communication Standard (HCS) to help ensure your employees have the knowledge and training they’ll need to protect themselves.

OSHA’s Hazard Communication Standard

OSHA’s HCS (1910.1200) requires employers to transmit information about hazards within the workplace. Most of the HCS provisions relate to classifying and labeling potentially harmful chemicals, but it also sets requirements for training employees.

In 2010, OSHA issued a memo to reiterate and clarify the Training Standards Policy Statement. Key points from the memo include:

• Regardless of the exact language used in OSHA safety standards, all synonyms of the terms "train" and "instruct" equate to “present information in a manner that employees receiving it are capable of understanding.”
• HCS references to “language and vocabulary employees can understand” require a nuanced approach. Here are a few examples:
  • If an employee does not speak or comprehend English, instruction must be provided in a language the employee can understand.
  • If the employee's vocabulary is limited, the training must account for that limitation.
  • If employees are not literate, telling them to read training materials will not satisfy the employer's training obligation.
  • If employers regularly 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 safety and health training to employees in the same manner.
• Finally, if an OSHA Compliance Officer determines that a deficiency exists in the employer's training program, the employer must demonstrate that employees were unable to understand the training and apply it to their specific workplace conditions.

How your organization can comply with OSHA’s HCS

In addition to OSHA’s Spanish-Language Compliance Assistance Resources, employers can work with language service providers to deliver instructive communications to their employees.

Here are a few ways CyraCom helps businesses provide understandable training content to limited-English proficient (LEP) or English as a second Language (ESL) employees:

Videos:

• Orientation videos
• Safety training videos including voiceover, subtitles, or captions

Employee Educational Materials:

• PowerPoint presentations
• Employee handbooks and manuals
• Safety and health policies, goals, and procedures

eLearning Modules or Lessons:

• Course content, including infographics, images, and graphics
• Tutorials, online presentations, slideshows, and assessments
• Transcription and/or translation of audio scripts
• Voiceover with audio localization
• Timecoded scripts for subtitles and/or closed captions

Why is OSHA compliance important?

In 2022, OSHA issued over 2,400 citations related to Hazard Communication. Workplace injuries can devastate employees and their families, while also being detrimental to a company’s bottom line.

U.S. businesses lose billions of dollars annually due to workplace injuries; lost productivity is only the tip of the iceberg. Companies often pay medical, legal, and workers’ compensation expenses, and may even receive an OSHA citation, which can cost up to $145,027 per violation.

Beyond fines and financial costs, compliance with OSHA safety regulations shows your employees you care about them. Seeking and retaining employees becomes much more challenging if your organization has a reputation for continued employee injuries.

Additional resources:

• Translating safety materials can help you maintain OSHA compliance
• When should you use captioning, subtitles, voiceover, or dubbing?
• 5 questions to ask your translation provider
• How to create better eLearning content

Need help translating your training materials? CyraCom offers free translation quotes!

Contact our team at translation@cyracom.com to ask questions or submit a request for a free quote.