â€œIf 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.â€
OSHAâ€™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, if employees are not literate, telling them to read training materials will not satisfy the employerâ€™s training obligation.
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.