P1. To develop, implement, and evaluate a safety and occupational health program that includes written plans in accordance with 29 CFR 1960, the OSHA Act of 1970, Executive Order (EO) 12196, and Job Corps policy.
P2. To develop and document all of the plans described in the following requirements, if applicable.
R1. Personal Protective Equipment (PPE) Plan
In accordance with 29 CFR 1910.132, centers are required to develop, implement, and maintain a written PPE plan and program that includes at least the following:
a. Perform hazard assessments for all trades and/or work areas to assess the need for PPE. Maintain hazard assessment records that identify hazards and risks, and document the type of PPE required. Develop procedures to notify the center Safety Officer when new processes are introduced or when existing processes change.
If a new career technical training (CTT) program is introduced, a hazard assessment must be performed to determine PPE needs according to training activities. Hazard assessment based upon other trades and activities cannot be the bases of the PPE requirements for a new trade.
b. Select PPE based on hazard assessments by the trade supervisor in conjunction with the center Safety Officer. Methods for selecting PPE are well-documented, appropriate, and properly implemented.
c. Develop a PPE training program that will address student and staff needs. The written training program includes:
1. When PPE use is necessary
2. What PPE is necessary
3. How to properly don (put on), doff (remove), adjust, and wear PPE
4. The proper care, maintenance, useful life, and disposal of PPE
d. Maintain PPE training records for students and staff for three years. Additional retention requirements are as follows:
1. Retain student training records for one year following completion of training or termination of enrollment.
2. Retain staff training records for one year following resignation or termination of employment.
e. Establish procedures to inspect, clean, and maintain PPE. Ensure that supervisors, staff, and students are trained in these procedures and follow the established criteria.
f. Establish procedures to remove damaged equipment from service.
R2. Fire Safety and Prevention Plan
All centers must develop and implement a Fire Safety and Prevention Plan that addresses the National Fire Protection Association (NFPA) Life Safety Code 101 requirements as referenced in 29 CFR 1910.39 and 1910.157.
Centers will establish a policy, based upon the proximity to emergency response personnel (i.e., fire and/or hazardous materials response teams) that specifies full evacuation or incipient stage fire suppression by staff in response to a fire alarm.
a. Fire Prevention Plan
The center Safety Officer must perform the following activities to ensure that students and staff are familiar with all center fire alarms and evacuation procedures:
1. Center Safety Officers must perform and log monthly inspections of:
(a) Fire alarm systems
(b) Sprinkler systems
(c) Illuminated exit signs
(d) Emergency lighting
(e) Fire extinguishers
2. Centers must conduct monthly fire drills during high student/staff activity levels and when students are in the dormitories. Center Safety Officers will document the accountability and timeliness of fire drills.
3. Centers must establish and implement a Fire Watch Plan, included as part of the Fire Prevention Plan, to be implemented when there is a nonfunctional alarm system. The Fire Watch Plan will include the following:
(a) Establishment of fire warden and security staff duties and responsibilities
(b) Establishment of minimum required equipment for security staff
(c) Establishment of a process for reporting fires and notifying building occupants
b. Fire Safety Plan Elements
The center Safety Officer must ensure that at least the following elements are included in the Fire Safety Plan:
1. List of major fire hazards and proper handling and storage procedures for hazardous materials
2. List of all potential ignition sources, control procedures, and the type of fire protection equipment or suppression system used to control a fire
3. List of staff responsible for maintaining fire protection equipment or systems to prevent or control ignition fires
4. List of staff responsible for control of fuel source hazards
5. List of staff responsible for sounding alarms and contacting local fire department or other appropriate officials
6. Evacuation and accountability procedures, including the posting of evacuation maps, assembly areas, and maintaining safe distance from affected buildings until areas are cleared for occupancy
7. Emergency notification telephone numbers
8. List of temporary shelters and contacts
9. List of staff responsible for assessing damage to center and coordinating re-entry to center or affected buildings
10. List of staff responsible for communications with local media, Regional Office, and National Office of Job Corps
All centers must provide ongoing fire prevention and fire extinguisher training for staff and students according to their roles and responsibilities within the Fire Prevention Plan. Training resources include state or local fire marshals, insurance companies, universities, or the Occupational Safety and Health Administration (OSHA). Training programs must be customized to center location, offerings, and programs, and must include the following elements, as appropriate:
1. Training for fire wardens and security staff
(a) Fire classes and the appropriate extinguishing agent
(b) Proper maintenance and use of fire extinguishers
(c) Evacuation and accountability procedures, as defined by NFPA Life Safety Code
(d) Proper use of warning equipment/alarm systems
(e) Fire watch system and alternative warning systems
(f) Fire warden responsibilities
(g) Fire safety inspections, including housekeeping practices, flammable and combustible waste materials accumulation, and inspection and maintenance of fire equipment or systems
2. Training for students
(a) Assigned evacuation routes and assembly areas
(b) Procedures for reporting a fire or potential for fire
(c) Procedures for disposal of combustible and flammable materials
(d) Location of smoking areas and receptacles
3. Training for staff
(a) Proper use of fire extinguishers
(b) Assigned evacuation routes and assembly areas
(c) Procedures for reporting a fire or potential for fire
(d) Procedures for disposal of combustible and flammable materials
(e) Location of smoking areas and receptacles
d. Required Documentation
Documentation of fire safety training, drills, and inspections must be maintained on center for three years and made available for review upon request.
e. Incipient Fire Suppression and Portable Fire Extinguishers
1. OSHA defines incipient fire as a fire in the initial or beginning stage that can be controlled or extinguished using a portable fire extinguisher, Class II standpipe, or small hose system without the need for protective clothing or equipment (e.g., breathing apparatus). OSHA requires centers to provide fire extinguishing equipment for an incipient fire. However, OSHA allows centers to address incipient fires and building evacuation in one of the following two ways:
(a) Evacuation of all or most of the building’s occupants to a safe area without attempting to fight the fire
(b) Evacuation of all building occupants except those who are properly trained and designated to use portable fire extinguishers
2. Fire prevention plans must comply with 1910.157, Portable Fire Extinguishers, according to the center’s established policy concerning incipient fires.
3. Incipient firefighting should be based upon a thorough hazard assessment, and proximity and response time of local fire department or emergency response team.
R3. Emergency Action Plan
Centers are required to develop an Emergency Action Plan (EAP) in accordance with 29 CFR 1910.38 if fire extinguishers are located in each building and students and staff are required to evacuate the building in the event of a fire or other emergency.
a. Emergency Action Plan (EAP) Elements
1. Procedures to handle hazards and threats including:
(a) Natural disasters typical for the geographic area in which the center is located; e.g., earthquakes, hurricanes, tornadoes, severe/extreme weather, blackouts, utility failures, and weather-related conditions
(b) Criminal activity including arson/fire, bomb threats, suspicious packages, vandalism, civil disturbance, and weapons on center
(c) Terrorist threats including radioactive, biological, or cyber attacks
(d) Medical emergencies, such as pandemic influenza or food poisoning (E. coli or Salmonella) outbreaks
(e) Other hazards specific to the surrounding area, such as hazardous materials spills or explosion
2. A list of emergency personnel and contact information (The Center Director or his or her designee shall act as the responsible official during the emergency.)
3. The Center Director or his or her designee must ensure that an Emergency Coordinator and Area/Floor Monitors are identified, and ensure that assistance is available for the physically challenged
4. Procedures for emergency situations that require centers to shelter-in-place, evacuate, and provide for mass care of students and staff
5. Identification of assembly areas on and off center for students and staff to relocate depending upon the nature of the emergency
6. Evacuation route maps indicating emergency exits, primary and secondary evacuation routes, location of fire extinguishers and fire alarm pull stations, and assembly points must be posted in all center buildings, including but not limited to:
(a) Residential facilities
(b) Child development centers, if applicable
(c) Academic facilities
(d) Food service facilities
(e) CTT facilities and classrooms
(f) Recreation areas
(h) Center maintenance
(i) Administration facilities
7. Procedures for staff required to remain on center after an evacuation to perform critical activities (e.g., shut down utilities) and secure the center
8. Procedures to account for students and staff after evacuation to assembly areas on and off center, including students training or working off center at the time of the emergency
9. Procedures for transporting students and staff to off-center assembly areas, including students training or working off center
10. Procedures for staff and students responsible for providing medical assistance (The plan should also provide for instances when individuals responsible for providing medical assistance are not available.)
11. An alarm system must be implemented that provides a distinctive sound or tone for each purpose (type of emergency and procedure) in accordance with 29 CFR 1910.165
12. Procedures for returning the center to normal operations following an emergency (Procedures should be emergency-specific.)
b. Emergency Response Drills
1. Centers must perform fire drills on a monthly basis. The drills should be performed during normal business hours and after hours.
2. Centers must participate in federal, state, and local emergency preparedness drills, including terrorist attack and pandemic outbreak response, when possible.
3. Centers must establish and maintain contact with federal, state, and local emergency response coordinators to ensure that current information regarding emergency response procedures is maintained.
4. All drill and post-drill activities designed to improve student and staff performance during drills must be documented and kept on file in the Safety Officer’s office and made available upon request.
5. Copies of drill performance and improvement reports must be maintained on the center for three years and made available for review upon request.
6. Centers must coordinate with the local emergency management authority, local health department, and local fire department to participate in federal, state, or local emergency response drills.
R4. Hazard Communication Plan
(See PRH Chapter 5, Section 5.16, R6.)
R5. Recreational Safety Plan
a. Water Safety (See PRH Chapter 3, Section 3.18, R5.)
1. Job Corps centers operating swimming pools must incorporate the Centers for Disease Control and Prevention (CDC) chlorine disinfection timetable for killing common germs.
2. Cleaning and disinfecting procedures must also include the area surrounding the pool, including chairs, towels, floors, etc., to prevent the onset of recreational water-related illnesses.
3. Provide staff and students with awareness training on the prevention of recreational water-related illnesses.
4. Ensure that swimming pool areas are secured after hours to prohibit unauthorized access.
5. Post proper warning signs, safety rules, and emergency response procedures.
6. Ensure that necessary rescue equipment is maintained in good working order and easily accessible.
b. General Recreational Safety
The Center Director must:
1. Ensure that students receive adequate training prior to engaging in recreational activities such as weight lifting, basketball, arts and crafts, etc.
2. Provide supervision during recreational activities to ensure that students follow proper techniques and are fit for the activity, thereby not placing the participant’s safety at above-normal risk and reducing the risk of injury at all times.
3. Advise students that “horseplay” is not tolerated during recreational activities.
4. Ensure that all recreational facilities and equipment are of safe design and free of known hazards.
5. Ensure that recreational and athletic equipment purchases meet safety guidelines established by agencies nationally recognized by the Consumer Product Safety Commission (CPSC).
c. Gymnasium and Recreational Equipment
1. Gym equipment must be positioned to allow for an unrestricted route of egress from the area during an emergency.
2. Personal protective equipment (PPE) such as helmets, padding, wrap-around eye protection, and gloves must be provided for students involved in recreational activities such as:
3. Recreational facilities and equipment must be inspected daily. Damaged equipment must be immediately removed from use and repaired or replaced as soon as fiscally possible.
d. Competitive Sports
To ensure student and staff safety and security during on- and off-center events, centers are encouraged to prepare plans that contain the following elements, at minimum:
1. Consider limiting participants and spectators to current Job Corps students and staff.
2. Ensure that there is sufficient supervision for off-center games and events. The recommended ratio is one staff member for every five students.
3. Coordinate security arrangements between visiting and host centers in advance of each activity. Visiting centers must provide a list of team members, Job Corps spectators, and player family members at least one week prior to the event. Limit entry into events to pre-approved spectators with proper identification.
4. Host centers are encouraged to arrange for additional security through local law enforcement when there is a history of past serious incidents.
5. Communicate safety and security procedures to athletes, staff, and spectators prior to the event.
R6. Asbestos Operations and Maintenance Plan
R7. Confined Space Entry Plan
A confined space is one that is large enough and configured in a manner that would allow a person to enter the space to perform work. The space has limited or restricted means of entry or exit and is not designed for continuous human occupancy. Hazards may also exist in the space, such as combustible gases, toxic materials, or mechanical or electrical hazards, or the space may be oxygen deficient.
A Confined Space Entry Plan is not necessary if one of the following is in place:
1. There are no confined spaces on center.
2. Students and staff are prohibited from entering or performing work in any confined space.
b. Confined Space Inventory
1. Centers must conduct a survey to identify and label all confined spaces located on center. Each space must be identified as “non-permit required” or “permit required.”
(a) A permit-required confined space is one that contains one or more of the following characteristics:
(1) Contains or has the potential to contain a hazardous atmosphere
(2) Contains a material that has the potential for engulfment or entrapment
(3) Has an internal configuration such that an entrant could be trapped or asphyxiated
(4) Contains any other serious safety hazard
(b) Non-permit-required confined space does not contain or have the potential to contain a hazardous atmosphere or any other hazard capable of causing death or serious physical harm.
(c) Re-evaluate all confined spaces annually and maintain documentation.
(d) Permit-required confined spaces are marked as such with appropriate signage.
(e) Ensure that permit-required confined spaces are locked or blocked to deter access (if possible).
2. Centers that require students, staff, or contractors to perform work in confined spaces are required to develop, implement, and maintain a Confined Space Entry program in accordance with 29 CFR 1910.146. The Plan must consist of the following elements:
(a) Designated confined space entry coordinator
(b) Entrant and supervisor responsibilities
(c) Non-permit-required confined space entry procedures
(d) Location-specific, permit-required confined space entry procedures
(e) List of center departments and/or career technical training (CTT) programs that require confined space entry
(f) Emergency procedures
(g) Training and documentation of training
3. Maintain confined-space-entry training records for students and staff for three years. Additional retention requirements are as follows:
(a) Retain student training records for one year following completion of training or termination of enrollment.
(b) Retain staff training records for one year following resignation or termination of employment.
4. Maintain cancelled entry permits for one year.
R8. Bloodborne Pathogens Plan
a. Centers must develop, implement, and maintain a Bloodborne Pathogens Control Plan that is in compliance with the OSHA Occupational Exposure to Bloodborne Pathogens; Needlestick and Other Sharp Injuries; Final Rule (29 CFR 1910.1030). The Plan, which is submitted to the Regional Office, must be reviewed and approved by the Regional Health Specialist. Once the Plan has been approved, the Plan does not need to be updated again until at least one of the following occurs:
1. New or revised PRH or regulatory standards necessitate revision of the plan.
2. Center introduces a new trade resulting in new potential exposure to bloodborne pathogens.
3. New engineering controls, including safer equipment or procedures, are introduced.
b. The plan must contain the following minimum requirements:
1. Identification of job classifications where there is high, medium, or low risk of exposure to blood or other potentially infectious materials
2. Explanation of the protective measures in effect to prevent occupational exposure to blood or other potentially infectious materials and a schedule and methods of compliance to be implemented
3. Schedule and method of implementation for administering Hepatitis B vaccination and conducting post-exposure evaluation and follow-up
(a) Job classifications with high risk of exposure will be provided the Hepatitis B vaccine.
(b) Job classifications with medium risk of exposure should be offered the vaccine or administered the vaccine as needed (i.e., post-exposure vaccine). Staff trained in CPR and first aid and required to render aid in an emergency as part of their job duties must be offered the Hepatitis B vaccine or administered the vaccine as stated above.
(c) Job classifications with low risk of exposure should be administered the vaccine as needed (i.e., post-exposure vaccine).
Regardless of job classification, staff who decline the Hepatitis B vaccine must sign a declination form in accordance with 29 CFR 1910.1030 Appendix A.
4. Schedule and method of implementation for communicating hazards to employees
5. Schedule and method of implementation for recordkeeping
6. Procedures for evaluating the circumstances of an exposure incident
R9. Respiratory Protection Plan
a. Centers must develop and implement a Respiratory Protection program, including a written plan in accordance with 29 CFR 1910.134, if any of the following conditions exist:
1. Center offers trades that could potentially expose students or staff to airborne contaminants that meet or exceed the OSHA eight-hour Permissible Exposure Limits (PELs) or action levels for known respiratory hazards.
2. Asbestos-containing building materials (ACBMs) are present and may be disturbed during routine maintenance, housekeeping, renovation, or demolition activities.
3. Lead-based paint or other materials are present and may be disturbed during renovation and demolition activities.
4. Students and staff are exposed or may be potentially exposed to airborne contaminants and disease through contact with individual(s) engaged in providing student and staff health services or engaged in allied health training.
b. Centers are not required to implement a written Respiratory Protection program if filtering face piece respirators (i.e., dust masks) are used on a voluntary basis and there is no potential for airborne particulate levels to meet or exceed the OSHA eight-hour PEL or action levels.
Voluntary use of tight-fitting, negative pressure air-purifying or powered air-purifying respirators requires a written plan, in accordance with 29 CFR 1910.134, Appendix D.
c. Centers must identify and evaluate respiratory hazards in the workplace through:
1. Air sampling and exposure monitoring;
2. National Institute for Occupational Safety and Health (NIOSH) trade-specific data regarding airborne contaminants; or
3. General or construction industry accepted best practices.
d. The Respiratory Protection program must contain worksite-specific procedures and elements for required respirator use.
e. Center Director or his or her designee must select a Respiratory Protection Program Coordinator to manage the center’s Respiratory Protection program.
f. The written Respiratory Protection Plan must contain the following elements:
1. Respirator selection procedures and criteria that ensure that exposure to hazardous substances occurs at or below maximum use concentrations
2. Medical surveillance for staff and students required to wear respirators
3. Fit-testing procedures for tight-fitting respirators
4. Procedures for the proper use of respirators in routine and emergency situations
5. Procedures and timelines for cleaning, disinfecting, storing, inspecting, repairing, discarding, and general maintenance of respirators
6. Procedures for ensuring air quality, quantity, and flow of breathing air for atmosphere-supplying respirators if applicable
7. Student and staff initial and annual refresher training that includes:
(a) Potential respiratory hazards during routine or emergency situations
(b) Proper use, donning, removal of respirators
(c) Limitations of respirator use
(d) Regular maintenance of respirators
8. Procedures for evaluating the effectiveness of the program
9. Medical evaluations conducted by a licensed health care professional in accordance with 29 CFR 1910.134(e)(1) through (e)(7)(iv)
10. Maintenance of respiratory protection training records for students and staff for three years. Additional retention requirements are as follows:
(a) Retain student training records for one year following completion of training or termination of enrollment.
(b) Retain staff training records for one year following resignation or termination of employment.
g. Centers must establish a cartridge change-out schedule in accordance with OSHA and manufacturers’ recommendations to ensure cartridge effectiveness.
h. Qualitative and quantitative fit-testing of tight-fitting respirators shall be done in accordance with 29 CFR 1910.134 Appendix A, Fit Testing Procedures (Mandatory). Fit-testing of respirators used to protect against asbestos or lead exposure shall be done in accordance with the appropriate OSHA standards.
R10. Hearing Conservation Plan
a. Centers must conduct noise monitoring at least every other year to identify potential sources of hazardous noise or whenever new noise sources are introduced into the working or training environment.
b. Centers must identify hazardous noise areas with warning signs or markings to ensure that hearing protection is used in those areas.
c. Centers must develop and implement a Hearing Conservation program in accordance with 29 CFR 1910.95 if the following conditions exist:
1. Results of noise measurements have identified hazardous noise sources that may result in staff or student exposures that exceed 85dB (decibels).
2. Exposure monitoring indicates that student and staff noise exposures equal or exceed an eight-hour time weighted average (TWA) of 85dB measured on the A-scale (slow response) or 50 percent dose.
d. The Hearing Conservation program (HCP) must consist of the following elements:
1. Monitoring program that identifies students and/or staff for inclusion in the HCP and to facilitate selection of appropriate hearing protectors.
2. Audiometric testing to monitor staff and students whose exposures equal or exceed an eight-hour TWA of 85dB, including:
(a) Baseline audiogram to be administered within six months of the initial exposure equal to or in excess of 85dB to be compared against subsequent audiograms.
(b) Audiograms administered at least annually following the baseline audiogram.
(c) Audiogram evaluation.
(d) Purchase of audiometric testing equipment is not required. However, if the center conducts audiometric testing, equipment and the testing environment must meet the requirements set forth in 29 CFR 1910.95, Appendices C and D.
If the center does not conduct audiometric testing, the center must ensure that individuals included in the Hearing Conservation program are administered audiograms in accordance with the OSHA standard.
(e) Audiometric testing must be performed by a licensed or certified audiologist, otolaryngologist, or other physician, or by a technician certified by the Council of Accreditation in Occupational Hearing Conservation, or who has demonstrated competence in administering audiometric examinations, obtaining valid audiograms, and properly using, maintaining, and checking calibration and proper function of the audiometers being used.
A technician who performs audiometric tests using a microprocessor audiometer does not need to be certified but must be responsible to an audiologist, otolaryngologist, or physician.
(f) Centers located in rural areas that are not equipped to conduct audiometric testing on center or find it difficult to locate audiometric testing centers must contact the Job Corps Regional Office Project Manager who will contact the National Office of Job Corps safety representative.
3. Hearing protector evaluation for specific hazardous noise environments to ensure attenuation to below 85dB. Evaluation methods should be done in accordance with 29 CFR 1910.95 Appendix B, “Methods for Estimating the Adequacy of Hearing Protection Attenuation.”
4. Selection and distribution of hearing protectors:
(a) Hearing protectors must be provided at no cost to staff or students.
(b) The hearing protectors selected should be appropriate for the task and provide the required noise attenuation.
(c) Students and staff who have not yet had a baseline audiogram should be issued hearing protection.
(d) Students or staff who have experienced a standard threshold shift must be issued hearing protectors.
5. Training that will be administered annually that includes but is not limited to the following:
(a) Effects of noise on hearing
(b) Purpose of hearing protectors
(c) Disadvantages, attenuation of various types of hearing protectors
(d) Instructions on selection, fitting, use, and care of hearing protectors
(e) Purpose of audiometric testing and an explanation of the test procedures
6. Staff and students, or their representatives, must have access to monitoring results, audiometric test results, and training materials in accordance with 29 CFR 1910.95.
7. Centers must maintain records as follows:
(a) Exposure monitoring results are maintained for two years.
(b) Audiometric testing results are maintained for the duration of the student’s enrollment and the duration of staff employment.
(c) Student and staff hearing protection attenuation and selection, and training records are maintained for two years.
8. Centers must retain all records associated with the hearing conservation program, upon transfer of center operations to another operator.
R11. Lead Exposure Plan
(See PRH Chapter 5, Section 5.16, R4.)
R12. Hexavalent Chromium Exposure Plan
(See PRH Chapter 5, Section 5.16, R9.)
R13. Lockout/Tagout Plan
a. Centers must develop written procedures for the control of hazardous energy in accordance with 29 CFR 1910.147 if students and staff are responsible for servicing or performing maintenance of machines or equipment.
b. A Lockout/Tagout Plan is not required when one of the following scenarios exists:
1. Servicing equipment that is powered by plugging into an electrical outlet and is under complete control of the individual performing the work
2. Making normal adjustments, including minor tool changes and other minor servicing activities that take place during normal production operations which are routine, repetitive, and integral to the use of that production equipment, as long as workers are effectively protected by alternative measures that provide effective machine safeguarding protection.
c. When a written Lockout/Tagout Plan is required, the program must include the following minimum elements:
1. Name of the machines or equipment and its purpose
2. Compliance requirements (policy)
3. Type of compliance enforcement for violation of policy
4. Name of students or staff affected and method of communication
5. Name of students or staff authorized to perform lockout/tagout
6. Type and magnitude of energy, its hazards, and the methods to control the energy
7. Type and location of machine or equipment operating controls
8. Type and location of energy isolating devices; lockout/tagout devices are sufficient in number, uniform, legible, understandable, and durable
9. Types of stored energy--methods to dissipate or restrain
10. Methods of verifying the isolation of the equipment
11. Training for affected and authorized students and staff
12. Method for evaluating lockout/tagout procedures at least annually and documenting results
13. Procedures for removing locks/tags when the owner of the lock or tag is not available
14. Plan is updated when changes in process, equipment, procedures, or audit warrants revision
R14. Powered Industrial Vehicle Plan
a. Centers that own or provide access to gas-powered or electric-powered fork trucks, tractors, platform lift trucks, motorized hand trucks (pallet jacks) or other specialized vehicles must develop a written Powered Industrial Vehicle Plan.
b. The plan must address the requirements outlined in 29 CFR 1910.178.
c. The plan must also include:
1. Complete list of covered vehicles
2. Fuel handling and storage procedures (if applicable)
3. Battery charging, changing, and storage procedures (if applicable)
4. Spill response procedures and fire prevention
5. Areas where trucks are used
6. Operator training
7. Daily inspection process
8. Process for removing vehicles from service
d. Powered industrial truck operators must be at least 18 years of age in accordance with the Fair Labor Standards Act (FLSA).
e. Operator training must be conducted by a certified trainer and the training must be in accordance with 29 CFR 1910.178(l).