WORKPLACE 

SAFETY AND 

HEALTH

Information on OSHA 

Training for Workers 

on Workplace 

Hazards

Report to the Chairman, Subcommittee 

on Health, Employment, Labor, and 

Pensions, Committee on Education and 

the Workforce, House of 

Representatives

February 2017

GAO-17-178

United States Government Accountability Office
United States Government Accountability Office

Highlights of GAO-17-178, a report to the 

Chairman, Subcommittee on Health,

Employment, Labor, and Pensions, Committee 

on Education and the Workforce, House of 

Representatives

February 2017

WORKPLACE SAFETY AND HEALTH

Information on OSHA Training for Workers on 

Workplace Hazards

What GAO Found

The Department of Labor’s Occupational Safety and Health Administration’s 

(OSHA) Outreach Training Program–which offers training on job hazard 

recognition and avoidance–reflects many of the attributes of a well-designed 

training program identified in GAO’s training guide. OSHA is not required to 

follow GAO’s training guide; however, the program’s design reflects at least one 

indicator for six of the seven attributes of a well-designed training program GAO 

has identified. For example, OSHA used an appropriate mix of centralized and 

decentralized approaches by developing core learning objectives and content 

requirements for the courses but allowed training providers to modify the 

curriculum to meet the specific needs of their audience. In addition, OSHA 

officials told GAO that they took into account the leading causes of worker 

deaths and the most common workplace safety and health violations to 

determine topics to be covered in the training.

OSHA documents successful course completion differently depending on 

whether training was delivered in-person or online, but it uses the same controls 

to prevent fraudulent completion cards from being issued. OSHA officials and the 

training providers GAO interviewed reported using several checks to prevent 

fraudulent completion cards from being issued, such as verifying course 

completion through automated and manual processes and comparing the 

number of cards requested to the number of registered students. Although 

OSHA does not require workers to complete Outreach Training, some workers 

may need to show proof of completion to satisfy requirements by their states, 

municipalities, employers, or unions. To obtain completion cards, Outreach 

trainers who deliver in-person training submit course information through a webbased system, while online training providers mail documentation to OSHA. 

OSHA processed 91 percent of the card requests from online training providers 

within 2 weeks, which is within the 30-day deadline OSHA has set for itself, 

according to GAO’s analysis of OSHA data. OSHA officials reported that they 

plan to allow all training providers to request completion cards electronically, but 

the agency has not established a timeline for implementing this new process. 

According to OSHA officials, the agency is taking steps to modify its process for 

selecting online training providers and plans to incorporate electronic requests 

for completion cards into the new process.

OSHA oversees the performance of training providers by routinely collecting and 

assessing data and investigating complaints and has taken some steps to 

assess the results of the program. Specifically, OSHA collects data from the 

training providers to help ensure that the training meets the program 

requirements and that the trainers are delivering the Outreach Training courses 

as intended. OSHA also investigates complaints it receives about training 

providers, including issues such as the trainer not spending enough time on 

required safety topics. To assess program results, OSHA tracks the number of

workers who take the Outreach Training courses to measure the reach of the 

program. According to OSHA data, from fiscal year 2000 to fiscal year 2016, the

number of workers trained more than quadrupled from 200,522 to 900,010. 

OSHA also receives test results and student evaluations of the courses from 

some of the Outreach Training providers.

View GAO-17-178. For more information, 

contact Allison Baw den at (202) 512-7215 or 

baw dena@gao.gov.

Why GAO Did This Study

In fiscal year 2016, approximately 

900,000 workers were trained through 

OSHA’s Outreach Training Program,

the agency’s primary mechanism for 

training workers on the basics of 

occupational safety and health. OSHA 

offers this training through OSHAauthorized in-person and online

training providers. GAO was asked to 

review OSHA’s administration of the 

program.

GAO examined (1) the extent to which 

the program aligns with leading 

practices in designing an effective 

training program, (2) the process for 

documenting successful completion of 

the training and whether internal 

controls are in place to assure 

completion is accurately documented, 

and (3) how OSHA oversees training 

providers and assesses the results of 

the program. GAO compared OSHA’s 

design and evaluation efforts for its 

training program with leading practices

in GAO’s training guide (GAO-04-

546G) and federal internal control 

standards, and analyzed fiscal year 

2012-2016 OSHA data (the most 

recent available) on time frames for 

processing completion card requests 

from online training providers. GAO 

also interviewed all nine online training 

providers and five in-person training 

providers, selected for having a high

number of participants in fiscal year 

2015, as well as OSHA officials.

GAO is not making recommendations 

in this report.
Page i GAO-17-178 OHSA Training

Letter 1

Background 3

OSHA’s Outreach Training Program Reflects Attributes of a WellDesigned Training Program 8

Outreach Training Providers Use Automated and Manual 

Processes and Controls to Document Students’ Successful 

Course Completion 12

OSHA Oversees Training Providers by Collecting Data and 

Investigating Complaints, and Has Taken Some Steps to 

Assess Program Results 16

Agency Comments 24

Appendix I GAO Contact and Staff Acknowledgments 26

Tables

Table 1: Extent to Which the Design of OSHA’s Outreach Training 

Program Reflects GAO Identified Attributes for a WellDesigned Training Program 9

Table 2: Selected OSHA Requirements for the 10-hour 

Construction Outreach Training Course 11

Table 3: 11 Performance Elements OSHA Uses to Assess the 

Education Centers’ Performance, Fiscal Year 2015 17

Figures

Figure 1: Growth in OSHA’s Outreach Training Program - Number 

of Workers Trained From Fiscal Year 2000 to 2016 7

Figure 2: OSHA Outreach Training Participants by Course Type, 

Fiscal Year 2016 8

Figure 3: Course Completion Card Processing for OSHA’s Inperson and Online Outreach Training 13

Figure 4: Results of OSHA’s Monitoring of the Education Centers 

by Performance Element, Fiscal Year 2015 19

Figure 5: OSHA Targets for Number of Workers Trained through 

Its Outreach Training Program and Actual Number of 

Workers Trained, Fiscal Years 2011-2016 22

Figure 6: OSHA’s Requirements for Assessing Outreach Training 

Compared to Kirkpatrick Levels of Evaluation 23

Contents
Page ii GAO-17-178 OHSA Training

Abbreviations

DOL Department of Labor 

Education Centers OSHA Training Institute Education Centers 

IACET International Association for Continuing Education 

and Training 

OSHA Occupational Safety and Health Administration 

OSH Act Occupational Safety and Health Act of 1970

This is a work of the U.S. government and is not subject to copyright protection in the 

United States. The published product may be reproduced and distributed in its entirety 

without further permission from GAO. However, because this work may contain 

copyrighted images or other material, permission from the copyright holder may be 

necessary if you wish to reproduce this material separately.
Page 1 GAO-17-178 OHSA Training

441 G St. N.W.

Washington, DC 20548

February 7, 2017

The Honorable Tim Walberg

Chairman

Subcommittee on Health, Employment, Labor, and Pensions

Committee on Education and the Workforce

House of Representatives

Dear Mr. Chairman:

In 2014, approximately 4,800 workers died on the job, and employers 

reported about 3 million nonfatal work-related injuries, according to data 

collected by the Department of Labor (DOL). DOL’s Occupational Safety 

and Health Administration (OSHA) is responsible for protecting the safety 

and health of the nation’s workers under the Occupational Safety and 

Health Act of 1970 (OSH Act).1 Ensuring that workers are properly trained 

in recognizing and avoiding workplace hazards is an important 

component in establishing and maintaining a safe and healthy workplace. 

In fiscal year 2016, approximately 900,000 workers were trained in job 

hazard recognition and avoidance through OSHA’s Outreach Training 

Program.2 In-person Outreach Training is provided to workers by 

Outreach trainers, safety professionals who have taken train-the-trainer 

courses at OSHA Training Institute Education Centers (Education 

Centers), which are a national network of nonprofit organizations 

authorized by OSHA to deliver various types of occupational safety and 

health training. Since 2001, OSHA has also allowed Outreach Training 

courses to be delivered online through authorized vendors. Participation 

in the program has grown substantially over time and although most 

workers take the training in-person, workers are increasingly taking the 

courses online. You asked us to review OSHA’s administration of the 

program, including the in-person and online training, and to determine 

how OSHA assesses the results of the program.

This report examines (1) the extent to which OSHA’s Outreach Training 

Program aligns with leading practices in designing an effective training 

 1 Pub. L. No. 91-596, 84 Stat. 1590 (codified as amended at 29 U.S.C. §§ 553, 651-78).

2 OSHA’s Outreach Training Program is designed for workers, but according to OSHA 

officials, individuals trained can include workers, employers, safety professionals, 

supervisors, and students in high school and college. In this report, we use the term 

“workers” to refer collectively to all of these groups. 

Letter
Page 2 GAO-17-178 OHSA Training

program, (2) the process OSHA uses to document students’ successful 

completion of the training and the extent to which internal controls are in 

place to assure completion is accurately documented, and (3) how OSHA 

oversees training providers and assesses the results of the program.

To address all of our objectives, we interviewed OSHA officials; 

representatives from all nine online training providers; and 

representatives from five Education Centers, selected because they had 

among the highest number of Outreach Training participants of all 27 

Education Centers in fiscal year 2015. Together, the 5 Education Centers 

accounted for 46 percent of workers trained in-person that year.3 We also 

observed three Outreach Training courses—two in-person and one 

online. Our observations from these training courses are intended to be 

illustrative, and are not generalizable. To determine the extent to which 

the design of the Outreach Training Program reflects leading practices, 

we compared the information obtained through interviews with OSHA 

officials and agency documentation to practices identified in GAO’s guide 

for assessing training and federal internal control standards.4 While 

GAO’s guide for assessing training is intended to help federal agencies 

review training and development programs for their employees, the 

attributes of effective training programs identified in the guide are derived 

from sources that are generally applicable to training and can be used to 

review a particular agency program or activity. To examine the process 

for documenting successful course completion, we reviewed (1) OSHA’s 

policies and procedures for issuing course completion cards and (2) other 

information obtained from OSHA, the online training providers, and the 

five Education Centers. We also analyzed the latest OSHA data available 

at the time of our review from fiscal years 2012 through 2016 on the 

timeframes for processing requests from online training providers for 

 3 There are currently 27 Education Centers.

4 GAO, Human Capital: A Guide for Assessing Strategic Training and Development Efforts 

in the Federal Government, GAO-04-546G (Washington, D.C.: Mar. 1, 2004) and GAO, 

Standards for Internal Control in the Federal Government, GAO-14-704G, (Washington, 

D.C.: Sept. 10, 2014). GAO’s guide for assessing training summarizes attributes of 

effective training programs related to four components of the training process: (1) 

planning/front-end analysis, (2) design/development, (3) implementation, and (4) 

evaluation. GAO obtained the information in this guide through consultations with 

government officials and experts in the private sector, academia, and nonprofit 

organizations; examinations of laws and regulations related to training and development in 

the federal government; and a review of the literature on training and development issues. 
Page 3 GAO-17-178 OHSA Training

course completion cards.5 We assessed the reliability of OSHA’s card 

processing data by (1) performing electronic testing of required data 

elements, (2) reviewing existing information about the data and the 

system that produced them, and (3) interviewing agency officials 

knowledgeable about the data. Based on these reviews, we determined 

that the data were sufficiently reliable for our purposes. To determine how 

OSHA oversees Outreach Training providers and assesses the results of 

the program, we reviewed OSHA’s reporting requirements for training 

providers, monitoring procedures, and agency monitoring reports. We 

also compared OSHA’s efforts to training evaluation practices in GAO’s 

training guide (GAO-04-546G) and federal internal control standards.

We conducted this performance audit from February 2016 to February 

2017 in accordance with generally accepted government auditing 

standards. Those standards require that we plan and perform the audit to 

obtain sufficient, appropriate evidence to provide a reasonable basis for 

our findings and conclusions based on our audit objectives. We believe 

that the evidence obtained provides a reasonable basis for our findings 

and conclusions based on our audit objectives.

OSHA is the federal agency responsible for administering the 

Occupational Safety and Health Act of 1970, as amended (OSH Act), 

which was enacted to assure safe and healthful working conditions for the 

nation’s workers.6 As authorized by the act, OSHA sets and enforces 

occupational safety and health standards, which are regulations that set 

forth specific safety and health requirements with which covered 

 5 We did not analyze data on how long it takes for the Education Centers to process 

course completion cards for workers who take the training in person because the 

Education Centers use different information systems to process the cards and no single 

data source exists that would allow us to analyze the data.

6 Pub. L. No. 91-596, 84 Stat. 1590 (codified as amended at 29 U.S.C. §§ 553, 651-678). 

Under the OSH Act, states may choose to operate their own occupational safety and 

health programs in accordance with state plans approved by OSHA. 

Background
Page 4 GAO-17-178 OHSA Training

employers must comply.7 Among its other responsibilities under the OSH 

Act, OSHA is also required to provide for the establishment and 

supervision of training programs to help workers and employers 

recognize, avoid, and prevent workplace safety and health hazards.8

The Outreach Training Program is the agency’s primary way to offer 

training for workers in the basics of occupational safety and health, 

according to OSHA.9 Outreach Training includes voluntary 10-hour and 

30-hour safety courses designed to provide basic hazard awareness 

training for workers in construction, maritime, and general industry, and a 

15-hour course for workers at disaster sites. The training covers how to 

recognize and prevent hazards on a jobsite, workers’ rights, employers’

responsibilities, and how to file a complaint. The 30-hour courses are 

intended to provide more in-depth training to workers who have some 

safety responsibility. Workers that successfully complete an OSHA 

Outreach Training Program course receive a student course completion 

card. The student course completion cards in Construction, General 

Industry, and Disaster Site do not have an expiration date; however, the

Maritime Outreach Training student course completion cards expire 5 

years after completing the training.

While OSHA does not require workers to take its Outreach Training 

courses, depending on their jobs and where the workers are located, they 

may be subject to other requirements to show an OSHA course 

 7 The OSH Act generally covers private sector employers and requires most federal 

agencies to maintain occupational safety and health programs that are consistent with 

OSHA standards. States that operate their own programs may cover private sector 

employers and must cover state and local government employers. These states may set 

and enforce their own standards, provided they are at least as effective as OSHA’s. OSHA 

enforces its occupational safety and health standards (referred to in this report as “OSHA 

standards”) by conducting inspections in response to complaints or on its own initiative, 

and may issue citations to employers it finds have violated the OSH Act or OSHA 

regulations.

8 29 U.S.C. § 670(c). 

9 In addition to the Outreach Training Program, OSHA also engages in other efforts to 

provide training to workers. For example, OSHA administers the Susan Harwood Training 

Grants Program, which provides competitive grants to nonprofit organizations to provide 

training and education programs for employers and workers on the recognition, 

avoidance, and prevention of workplace safety and health hazards. OSHA also provides 

training for federal and state compliance officers through its OSHA Training Institute; 

private sector workers and federal workers from agencies other than OSHA may receive 

training from the OSHA Training Institute when space is available.
Page 5 GAO-17-178 OHSA Training

completion card to demonstrate they completed the training.10 For 

example, some states, municipalities, unions, and employers may require 

workers to take an OSHA Outreach Training course as a condition of 

employment for certain jobs, and OSHA maintains a list of states and 

municipalities that have such a requirement. According to OSHA’s list, 

seven states (Connecticut, Massachusetts, Missouri, Nevada, New 

Hampshire, New York, and Rhode Island), and three municipalities 

(Miami-Dade County, New York City, and Philadelphia) require certain 

workers to take some form of OSHA Outreach Training or an equivalent 

training. For example, all of these states and municipalities require certain 

workers on public construction projects to take a 10-hour construction 

safety course. Some, including Nevada and Philadelphia, also require this 

training for workers on private construction projects.

Outreach Training courses are delivered by OSHA-authorized external 

training providers that receive no funding from OSHA, but instead, rely on 

tuition and fees from training participants to cover the cost of the training. 

The types of training providers include Education Centers, which train 

Outreach trainers to deliver in-person Outreach Training courses to 

workers, and online training providers.

• Education Centers:OSHA has nonfinancial cooperative agreements 

with 27 Education Centers–which are typically universities–to provide 

occupational safety and health training to workers and employers on 

behalf of OSHA.11 The Education Centers have two main roles under 

the Outreach Training Program: (1) conduct in-person train-the-trainer 

courses to qualified individuals interested in becoming authorized 

Outreach trainers; and (2) act as an authorized training organization

for the Outreach trainers by monitoring Outreach trainers through 

records audits and training observations and by processing course 

completion cards that Outreach trainers request on behalf of the 

workers who take their courses. OSHA selected the Education 

Centers through a formal competitive application process. Successful 

 10 Although some OSHA standards require covered employers to provide certain types of 

training for their workers, OSHA Outreach Training does not fulfill the training 

requirements found in OSHA standards. 

11 In addition to their Outreach Training Program responsibilities, the Education Centers 

are responsible for delivering other occupational safety and health courses to workers and 

employers on behalf of OSHA. The other offerings include courses on OSHA standards 

and special topics, such as recordkeeping, machine guarding, and fall arrest systems.

Types of Outreach 

Training Providers
Page 6 GAO-17-178 OHSA Training

applicants entered into 5-year nonfinancial cooperative agreements 

with OSHA.

• Outreach trainers:For in-person training, Education Centers 

authorize Outreach trainers to provide the training to workers. To 

become an authorized Outreach trainer, individuals must meet 

industry safety experience requirements, complete a training course 

on the applicable OSHA standards, and successfully complete a trainthe-trainer course at one of the Education Centers. Outreach trainers 

are authorized to provide in-person training to workers for 4 years 

from the date that the trainer course is completed and must 

successfully complete an update course at an Education Center to 

maintain authorization. Currently, there are approximately 30,000 

authorized Outreach trainers, according to OSHA officials.

• Online training providers:Online training is provided by nine OSHAauthorized online training providers, including eight companies and 

one Education Center. OSHA used a multi-phase process to select 

the current online training providers that is described in OSHA 

guidance.12 The guidance provided the requirements for establishing 

an online Outreach Training course and a process for OSHA 

authorization. The phases of the process included: (1) submission of a 

description of the online training program, target audience, and 

expected impact of the program; (2) submission of a detailed written 

description of the online training plan; (3) self-verification audit where 

the online training provider reviews the training against OSHA’s 

guidance; and (4) OSHA’s review of the completed online training to 

verify that the program is consistent with OSHA’s guidance.

In recent years, OSHA has attempted to change its process for selecting 

the online training providers, but those attempts have been challenged in 

court. In 2011 and 2014, the agency issued public solicitations, intending 

to enter into nonfinancial cooperative agreements or contracts with 

selected providers. Both solicitations were found to have procedural 

deficiencies by the U.S. Court of Federal Claims after online training 

companies challenged them in court.13 According to OSHA officials, the 

agency has revised the solicitation to address the court rulings, but no 

date has been set for issuing the revised solicitation. Currently, the nine 

 12 OSHA, Outreach Training Program – Online Training Guidance (February 2009). 

13 For details, see 360Training.com, Inc., v. United States, 104 Fed. Cl. 575 (2012), 

360Training.com, Inc., v. United States, 106 Fed. Cl. 177 (2012), and American Safety 

Council, Inc. v. United States, 122 Fed. Cl. 426 (2015). 
Page 7 GAO-17-178 OHSA Training

online training providers provide OSHA Outreach Training under their 

2009 authorization.

Participation in the Outreach Training Program has grown substantially 

over time. The number of workers trained more than quadrupled from 

200,522 in fiscal year 2000 to 900,010 in fiscal year 2016. The vast 

majority of participants take the courses in-person; however, the number 

of participants taking the courses online has increased in recent years 

(see fig. 1). In fiscal year 2016, 70 percent of participants took the 

Outreach Training courses in person, and 30 percent took the courses 

online. The number of participants taking the courses online increased 

from 19 percent in fiscal year 2011 to 30 percent in fiscal year 2016.

Figure 1: Growth in OSHA’s Outreach Training Program - Number of Workers 

Trained From Fiscal Year 2000 to 2016

The courses tailored to the construction industry are the most popular. In 

fiscal year 2016, about 75 percent of the Outreach Training participants 

took the construction courses, and 24 percent took the general industry 

courses (see fig. 2).

Program Participation
Page 8 GAO-17-178 OHSA Training

Figure 2: OSHA Outreach Training Participants by Course Type, Fiscal Year 2016

Note: Numbers do not add to 100 percent due to rounding. Maritime category includes the number of 

training participants in both the 10- and 30-hour Maritime courses. The Disaster site w orker course is 

a 15-hour course.

OSHA’s Outreach Training Program reflects attributes of a well-designed 

training program. GAO’s training guide identifies attributes of a welldesigned training program and suggests the kinds of documentation to 

look for that indicate that a training program has a particular attribute in 

place.14 OSHA is not required to follow GAO’s training guide, however, 

we found that the program’s design reflected at least one indicator for six 

of the seven attributes of a well-designed training program described in 

the guide (see table 1).

 14 GAO-04-546G 

OSHA’s Outreach 

Training Program 

Reflects Attributes of 

a Well-Designed 

Training Program
Page 9 GAO-17-178 OHSA Training

Table 1: Extent to Which the Design of OSHA’s Outreach Training Program Reflects GAO Identified Attributes for a WellDesigned Training Program

Attribute

Indicators of this Attribute in OSHA’s Design of the Outreach Training 

Program 

Ensures that training is connected to improving 

individual and agency performance in achieving 

specific results 

The program is linked to the Department of Labor’s (DOL) goal in its strategic 

plan to improve workplace safety and health.

Integrates with other strategies to improve 

performance and meet emerging demands

The program complements the agency’s other efforts, such as enforcing OSHA 

standards, to improve workplace safety and health. 

Uses the most appropriate mix of centralized and 

decentralized approaches for its training 

OSHA uses a combination of centralized and decentralized approaches by 

centrally setting the learning objectives, establishing detailed content 

requirements, and developing training materials, while allowing training providers 

to modify the curriculum to meet the specific needs of their audience.

Uses criteria in determining whether to design 

training programs in-house or obtain from a 

contractor or other external sources

GAO did not identify any indicators of this attribute.

Compares the merits of different delivery 

mechanisms (such as classroom or computerbased training) and determines what mix to use to 

ensure efficient and cost-effective delivery 

OSHA decided to use the train-the-trainer format for the in-person training to 

expand the reach of the program and increase training availability.

Since 2001, OSHA has also allowed the 10- and 30-hour construction and 

general industry Outreach Training courses to be delivered in an online format to 

make the training more readily available to workers.

Determines a targeted level of improved 

performance in order to ensure that the cost of a 

training program is appropriate to achieve the 

anticipated benefit 

OSHA sets yearly targets for the number of workers trained through the 

Outreach Training Program to expand the reach of the program, which is linked 

to DOL’s strategic plan goal to improve workplace safety and health. The cost of 

the program is low because the training is funded through course fees paid by 

training participants; only OSHA’s oversight of the program is federally funded.

Incorporates measures of effectiveness into 

courses it designs 

OSHA requires the Education Centers and online training providers to take steps 

to evaluate the effectiveness of their courses. Specifically, Education Centers 

and online training providers administer standard student evaluations that are 

provided to OSHA. The student evaluations provide Education Centers and 

online training providers with information about students’ perceptions of the 

training courses.

Source: GAO review of Occupational Safety and Health Administration (OSHA) Outreach Training Program documentation compared to training design attributes in GAO-04-546G. | GAO-17-178

OSHA took steps to design the Outreach Training Program so that 

workers receive consistent and quality training by using data to identify 

the content of the training, developing training materials, and issuing 

detailed requirements for training providers. According to OSHA officials, 

the content of the training was selected after the agency reviewed data on 

the leading causes of worker deaths and the most frequently cited OSHA 

standards.15 OSHA also developed training materials that training 

 15 As previously mentioned, if OSHA determines, as a result of a worksite inspection, that 

an employer has violated the OSH Act or an OSHA standard, it may issue a citation to that 

employer. 
Page 10 GAO-17-178 OHSA Training

providers can use, including presentations, lesson plans, fact sheets, and 

tests. In addition, OSHA developed detailed requirements regarding the 

content and delivery of the training that apply to all Outreach Training 

providers to improve the quality of the courses and ensure the integrity of 

its authorized trainers. Specifically, in 2011, OSHA replaced its previous 

program guidelines with a revised policy document establishing 

requirements that apply to all Outreach Training providers, including inperson and online training providers. OSHA issued general Outreach 

Training Program Requirements and separate Industry Procedures for the 

Construction, General Industry, Maritime, and Disaster Site courses. The 

requirements and industry-specific procedures identify the learning 

objectives for the courses, the topics that must be covered, and the 

amount of time training providers must spend on each topic, among other 

things. OSHA most recently revised the Outreach Training Program 

Requirements and industry-specific procedures in January of 2017.16

OSHA used a combination of centralized and decentralized approaches 

to design the Outreach Training Program. GAO’s training guide suggests 

agencies consider the advantages and disadvantages of using 

centralized and decentralized approaches to designing training programs. 

Centralizing design can enhance consistency of training content whereas 

a decentralized approach to training design can enable agencies to tailor 

training programs to better meet the unique needs of the intended 

audience. OSHA used a combination of approaches by centrally setting 

the learning objectives and establishing detailed content requirements, 

while also allowing training providers to supplement the curriculum to 

meet the specific needs of their audience. For example, while OSHA 

requires all Outreach Training courses to include 2 hours of introductory 

information about OSHA, training providers have some flexibility to 

develop the rest of the curriculum as long as they cover the required 

topics and meet the time requirements. Table 2 provides a summary of 

OSHA’s topic and time requirements for the 10-hour construction 

Outreach Training course.

 16 OSHA, OSHA Outreach Training Program Requirements (Arlington Heights, IL: January 

2017). OSHA, Outreach Training Program Construction Industry Procedures (Arlington 

Heights, IL: January 2017). OSHA, Outreach Training Program General Industry 

Procedures (Arlington Heights, IL: January 2017). OSHA, Outreach Training Program 

Maritime Industry Procedures (Arlington Heights, IL: January 2017). OSHA, Outreach 

Training Program Disaster Site Worker Procedures (Arlington Heights, IL: January 2017).

The revised requirements and procedures take effect April 1, 2017. Unless otherwise 

indicated, in this report we refer to the previous versions of the requirements and 

procedures, which were in effect during the course of our review.
Page 11 GAO-17-178 OHSA Training

Table 2: Selected OSHA Requirements for the 10-hour Construction Outreach 

Training Course

Mandatory Topics

Introduction to OSHA (2 hours)

• Introduces workers to OSHA, OSHA standards, and the inspection process

• Covers workers’ rights, employer responsibilities, how to file a complaint, and worker 

safety and health resources

OSHA Focus Four Hazards (4 hours)

• Covers how to recognize the four leading causes of construction fatalities: Falls, 

Electrocution, Struck-By, Caught-In or Between

Personal Protective and Lifesaving Equipment (30 minutes)

Health Hazards in Construction (30 minutes)

Elective Topics (Must spend 2 hours on at least two of the following topics)

• Cranes, Derricks, Hoists, Elevators, Conveyors

• Excavations

• Materials Handling, Storage, Use, and Disposal

• Scaffolds

• Stairways and Ladders

• Tools – Hand and Power

Other (1 hour)

• Trainer can cover other construction industry hazards or polices and/or expand on 

the mandatory or elective topics

Source: GAO summary of selected Occupational Health and Safety Administration (OSHA) requirements in OSHA’s Outreach Training 

Program Construction Industry Procedures. | GAO-17-178

In addition, although OSHA does not require any accreditation for 

Outreach Training providers, OSHA’s Directorate of Training and 

Education, which designed the Outreach Training Program, and several 

of the online training providers, reported that they are accredited by the 

International Association for Continuing Education and Training (IACET). 

IACET accreditation involves an audit of the organization’s training 

program that benchmarks the organization against a national standard 
Page 12 GAO-17-178 OHSA Training

called the IACET Standard for Continuing Education and Training.17

IACET officials review the training provider’s application and document 

that the standard is being followed by the organization and that the 

attestations in the application are accurate by conducting a site visit. 

IACET-accredited training providers must demonstrate that they have 

processes in place to ensure that the individuals involved in training 

design are qualified and that the content and instructional methods used 

are appropriate for the learning objectives of the training, among other 

things. According to OSHA officials, having OSHA’s Directorate of 

Training and Education become IACET-accredited as a continuing 

education provider demonstrates the agency’s commitment to high 

standards for the agency’s training programs. The Education Centers we 

interviewed had a different form of accreditation associated with their 

universities.

To obtain course completion cards, which training providers distribute to 

workers who complete the training, training providers must submit class 

documentation through either an automated or paper-based process. 

Outreach trainers–who deliver in-person training to workers–request 

cards by submitting class documentation electronically through a webbased system to the Education Center where the trainer was authorized. 

If approved, the Outreach trainers are sent wallet-sized plastic cards for 

the workers, each with a Quick Response (QR) code that can be scanned 

with a smart phone, allowing employers and workers to verify the 

authenticity of the card.18 In contrast, online training providers mail class 

documentation, such as student names, course completion dates, test 

results, and student evaluations of the courses, to OSHA to obtain cards 

for the workers who take the training online. If approved, the online 

training providers are sent wallet-sized paper cards for the workers. The 

online training provider then prints the student names on the paper cards 

and distributes them to the workers (see fig.3).

 17 The American National Standards Institute/IACET Standard for Continuing Education 

and Training measures all aspects of a training provider’s program development across 

ten categories: Continuing Education and Training Organization, Responsibility and 

Control, Learning Environment and Support Systems, Learning Event Planning, Learning 

Outcomes, Planning and Instructional Personnel, Content and Instructional Methods, 

Assessment of Learning Outcomes, Awarding Continuing Education Units and Maintaining 

Learner Records, and Program Evaluation.

18 When the QR code is scanned, it connects to a website with information including the 

worker’s name, trainer name, date of issuance, and the Education Center that produced 

the card.

Outreach Training 

Providers Use 

Automated and 

Manual Processes 

and Controls to 

Document Students’

Successful Course 

Completion
Page 13 GAO-17-178 OHSA Training

Figure 3: Course Completion Card Processing for OSHA’s In-person and Online 

Outreach Training

OSHA typically processed the course completion cards within 2 weeks of 

receiving the request from the online training providers, according to our 

analysis of OSHA data.19 OSHA has 30 days to process course 

completion cards after receiving an online training provider’s request for 

cards, according to an internal deadline set by OSHA. In our analysis of 

OSHA fiscal year 2012-2016 data, we found that OSHA took 7 days on 

average to process the cards, and the processing time ranged from 

 19 We did not analyze data on how long it takes for the Education Centers to process 

course completion cards for workers who take the training in-person because the 

Education Centers use different information systems to process the cards and there is no 

single data source that would allow us to analyze the data. Officials from the five 

Education Centers we interviewed reported taking between 3 and14 days on average to 

process the cards. According to OSHA officials, the agency has not received complaints 

about the timely processing of course completion cards by the Education Centers. 
Page 14 GAO-17-178 OHSA Training

processing the cards the day OSHA received the request to 51 days. 

Two-thirds of the card requests were processed in a week or less, and 91 

percent were processed within 2 weeks.

However, six of the nine online training providers we interviewed said 

OSHA’s paper-based system for processing course completion cards 

contributed to delays in issuing cards to workers. For example, one online 

training provider said it mails OSHA between 200 and 300 pages of class 

documentation on a bi-weekly basis and it takes OSHA up to 4 weeks to 

mail the cards back to them. Three of the nine online training providers 

we interviewed gave examples of how lengthy processing times can 

negatively impact workers. One online training provider that serves 

younger workers said delays can be problematic, especially at the end of 

the school semester, because if the student does not get the course 

completion card in time, he or she may not have the required documents 

needed to start their summer job. Another online training provider said 

that waiting for OSHA to process the cards causes anxiety for many 

students, as 3 or 4 weeks is a long time to wait for something required 

before they can get a job. A third online training provider said there have 

been instances where their students could not start working on the job 

site because the student did not have their course completion card and 

the employer or union refused to accept the online training provider’s 

certificate of completion. While online training providers have noted these 

issues, the two national organizations we interviewed that represent 

employers and unions said that they have not received complaints from 

workers regarding delays in getting their course completion cards or that 

delays affected their ability to start working at their job site.20

Differences in the process for issuing course completion cards stem from 

the history of the program, according to OSHA officials. When OSHA 

began partnering with the Education Centers to conduct OSHA Training 

Institute courses in 1992, the agency required individual Outreach trainers 

to request course completion cards for workers through the Education 

Center where they received authorization to serve as trainers. According 

to OSHA officials, in 2001, when OSHA began allowing the 10- and 30-

hour construction and general industry Outreach Training courses to be 

delivered in an online format, OSHA decided to serve as the authorizer 

for the online providers.

 20 We interviewed representatives from the National Safety Council and North America’s 

Building Trades Union. 
Page 15 GAO-17-178 OHSA Training

OSHA officials told us that they are planning to allow the online training 

providers to request cards electronically by having the Education Centers 

take over processing the course completion cards for the online training 

providers, but OSHA has not established a timeline for implementing this 

new process. According to OSHA officials, the agency plans to include a 

process for electronically requesting course completion cards in 

conjunction with the revised solicitation for selecting the online training 

providers that OSHA is finalizing. OSHA also intends to make the plastic 

cards available to workers who take the courses online. Having the 

Education Centers issue course completion cards to online providers may 

help to speed the time for issuing these cards to workers. However, the 

online training providers we interviewed generally said that they believe 

that they could issue the cards more quickly if they issued the cards 

themselves. OSHA officials told us they considered allowing the online 

training providers to process and print their own OSHA cards but decided 

not to because they want to limit the number of organizations that have 

access to the course completion cards.

Training providers and OSHA officials reported using automated and 

manual checks to help ensure that cards are requested only for the 

students who successfully complete the courses and that the courses 

meet OSHA’s Outreach Training Program requirements. Both the 

Education Centers and online training providers reported using 

information systems that automatically check whether the students have 

taken courses that met OSHA requirements, such as spending the 

minimum amount of time on specific topics. Some of the online and inperson training providers reported also using staff to manually verify the 

information in the class documentation submitted to obtain course 

completion cards. The online training providers reported using user 

names and passwords to verify that the person registered for the course 

is the person completing the course. In addition, some of the online 

training providers reported that they are capable of using biometric data, 

such as voice recognition or keystroke analysis, to authenticate students. 

OSHA manually compares the number of cards requested by the online 

training providers to the number of student names listed in the class 

documentation and logs the unique course completion card numbers into 

a spreadsheet.

Use of internal controls in the course completion card process is 

important to protect the integrity of the program. OSHA works with DOL’s 

Office of Inspector General to investigate and address fraudulent activity. 

According to OSHA officials, there have been relatively few cases of fraud 

in the program. OSHA refers fraudulent activity to DOL’s Office of 
Page 16 GAO-17-178 OHSA Training

Inspector General, and trainers caught falsifying information may be 

subject to criminal prosecution. DOL’s Office of Inspector General 

investigated four cases of fraud involving OSHA training over the last 3 

years, according to Office of Inspector General officials. Examples of 

fraud cases they identified include an Outreach trainer selling course 

completion cards to construction workers without providing the training 

and an individual conspiring with an Outreach trainer to sell fraudulent 

OSHA course completion cards.

OSHA oversees the in-person training providers on an ongoing basis by 

collecting and assessing data from the Education Centers, including:

• Course information: OSHA collects data on the train-the-trainer 

courses the Education Centers deliver to individuals interested in 

becoming authorized Outreach trainers, including the names of the 

courses presented each month, training locations and dates, 

instructor names, total students, total instructional hours, and test 

results.

• Course completion card processing: OSHA collects data on the 

number of course completion cards the Education Centers process 

each month for their authorized Outreach trainers.

• Monitoring activities: OSHA collects data on the number of record 

audits and training observations the Education Centers conduct on 

their authorized Outreach trainers to check that the in-person training 

delivered to workers complies with OSHA’s Outreach Training 

Program requirements and procedures.

OSHA assesses the Education Centers’ performance on 11 performance 

elements (see table 3), which relate to the Education Centers’ Outreach 

OSHA Oversees 

Training Providers by 

Collecting Data and 

Investigating 

Complaints, and Has 

Taken Some Steps to 

Assess Program 

Results

OSHA Oversees Training 

Providers by Routinely 

Collecting and Assessing 

Data and Investigating 

Complaints
Page 17 GAO-17-178 OHSA Training

Training Program responsibilities and their other responsibilities outlined 

in their nonfinancial cooperative agreements with OSHA.21

Table 3: 11 Performance Elements OSHA Uses to Assess the Education Centers’ Performance, Fiscal Year 2015

Performance Element Description

Number of students trained Number of students who completed occupational safety and health courses at the Education 

Centers.

Present occupational safety and 

health courses

Number of occupational safety and health courses delivered at the Education Centers.

Extent of regional training The extent to which each Education Center offers courses to ensure sufficient coverage throughout 

the OSHA Region covered by that Education Center. 

Outreach monitoring plan 

activities

The extent to which the Education Centers monitor the training provided by the Outreach trainers by 

completing a minimum number of records audits and training observations.

Course documentation The extent to which the Education Centers ensure students have met all course prerequisites and 

provide copies of course documentation to OSHA within established timeframes.

Student surveys The extent to which the Education Centers submit complete and accurate student surveys to OSHA 

within 2 weeks of the course completion date.

Reporting The extent to which the Education Centers provide accurate and timely reports to OSHA on the 

courses taught at the centers. 

Other Outreach Training 

Program administrative 

requirements

The extent to which the Education Centers fulfill administrative duties, including issuing course 

completion cards in a timely manner, maintaining trainer records, and assisting OSHA with fraud 

investigations. 

Partnering efforts The extent to which the Education Centers partner with OSHA Regional and Area offices on 

training, participate on project teams with other Education Centers, and support agency priorities. 

Customer service The extent to which the Education Centers respond to inquiries from OSHA and the public in a 

timely manner, minimize course cancellations, and facilitate necessary refunds in a satisfactory 

manner. 

Marketing and promotion The extent to which the Education Centers effectively and appropriately promote the courses 

offered at the centers.

Source: GAO review of Occupational Safety and Health Administration (OSHA) documentation. | GAO-17-178

Note: The occupational safety and health courses referred to in this table include the train-the-trainer 

courses for Outreach trainers, as well as other training provided by the Education Centers, such as 

courses on OSHA standards and special topics, such as recordkeeping, machine guarding, and fall 

arrest systems.

OSHA uses the data it collects from the Education Centers to assess the 

extent to which the Education Centers are meeting their performance 

goals in an annual appraisal. OSHA rates the Education Centers on a 

 21 As previously discussed, in addition to the Outreach Training Program responsibilities, 

the Education Centers are responsible for delivering other occupational safety and health 

courses to workers and employers on behalf of OSHA. The other courses include courses 

on OSHA standards and special topics, such as recordkeeping, machine guarding, and 

fall arrest systems. 
Page 18 GAO-17-178 OHSA Training

three-point scale of “outstanding,” “satisfactory,” or “area for 

improvement” for seven performance elements and on a two-point scale 

of “satisfactory” and “area for improvement” for the remaining four 

performance elements.22 For example, in OSHA’s appraisals for fiscal 

year 2015, OSHA rated 22 of 27 Education Centers an “outstanding” or 

“satisfactory” rating on their Outreach trainer monitoring and identified this 

as an “area of improvement” for 5 Education Centers because they did 

not take certain actions, such as conducting enough records audits and 

training observations (see fig. 4).

 22 A rating of outstanding, satisfactory, or area for improvement is provided for the Number 

of Students Trained, Present Occupational Safety and Health Courses, Extent of Regional 

Training, Outreach Monitoring Plan Activities, Course Documentation, Student Surveys 

and, Reporting Performance Elements.A rating of Satisfactory and Area for Improvement 

is provided for the Other Outreach Training Program Administrative Requirements, 

Partnering Efforts, Customer Service, and Marketing and Promotion performance 

elements.
Page 19 GAO-17-178 OHSA Training

Figure 4: Results of OSHA’s Monitoring of the Education Centers by Performance 

Element, Fiscal Year 2015

OSHA follows up with the Education Centers that have received “area for 

improvement” ratings to ensure they are taking corrective action. OSHA 

checks whether corrective actions are implemented by conducting 

quarterly course documentation audits, annual conference calls, and 

periodic on-site audits, as well as by developing mid-year status reports. 

In addition, the program coordinator for the OSHA Training Institute 

Education Center Program interacts with the Education Centers 

throughout the year to ensure they are meeting performance goals, 

according to OSHA officials.

OSHA also investigates complaints it receives about Outreach trainers 

from the general public, referrals from the Education Centers based on 

their Outreach trainer monitoring, and requests by other OSHA regional 

offices. OSHA investigates allegations that an Outreach trainer may not 
Page 20 GAO-17-178 OHSA Training

be in compliance with OSHA’s Outreach Training Program Requirements 

and allegations of potential fraud. For example, OSHA may investigate 

cases where an Outreach trainer fails to respond to audit requests from 

an Education Center or fails to provide training that meets OSHA’s 

requirements, such as spending enough time on required topics. OSHA 

will notify the Outreach trainer of its findings from the investigation and 

allow the trainer 15 days to address the findings identified in the 

notification. If the trainer does not respond within this timeframe, OSHA 

may suspend the trainer indefinitely until a response is received. The 

trainers can appeal OSHA’s initial decision. If there is an appeal, OSHA 

will review it and make a final decision, which may result in the Outreach 

trainer being subjected to disciplinary actions, including probation, 

suspension, or revocation of the Outreach trainer authorization.23 As of 

October 2016, 107 Outreach trainers, which is less than 1 percent of the 

approximately 30,000 Outreach trainers, have had their status as 

authorized Outreach trainers suspended or revoked by OSHA as a result 

of failing to comply with the Outreach Training Program requirements and 

procedures.

OSHA officials said that they oversee the online training providers by 

collecting updated course information twice per year and investigating 

any complaints about the training. In 2009, OSHA required that online 

training providers complete an initial multi-phase process to develop 

online Outreach Training courses that meet OSHA’s requirements.24

According to OSHA officials, after they initially approved the online 

training providers, OSHA monitoring has consisted of responding to 

complaints about the training, requiring online providers to submit 

updated information on their courses twice per year, and requiring that 

providers self-certify twice per year that their training meets OSHA’s 

requirements. OSHA investigates complaints about the online training 

providers by first sending them a notification letter describing the issue. 

Examples of issues OSHA has investigated include cases where an 

 23 Outreach trainers who are placed on probation can continue to teach Outreach Training 

courses if they give the Education Center advanced notice of their planned courses, 

submit advance notice of their promotional materials for their courses, and submit 

additional documentation for the classes conducted. Trainers who have been suspended 

cannot conduct Outreach training during the suspension period but can request to be 

reinstated when the suspension has been completed. Trainers whose trainer status has 

been revoked are permanently barred from teaching Outreach Training courses. 

24 This process is described in OSHA’s online training guidance. See OSHA, Outreach 

Training Program – Online Training Guidance (February 2009).
Page 21 GAO-17-178 OHSA Training

online provider incorrectly advertised the courses or offered the training 

outside of OSHA’s geographic jurisdiction.25 The online provider has 15 

days to respond to OSHA, and if OSHA determines they have violated 

applicable requirements, OSHA may suspend, terminate, or put them on 

probation. Online providers who are placed on probation are required to 

submit monthly self-certifications to OSHA that their program is in 

compliance with OSHA’s online training guidance. OSHA did not establish 

a performance assessment process for online training providers when the 

current providers were selected in 2009, but according to officials, the 

agency is in the process of finalizing a public solicitation for a new model 

for authorizing online providers that they said will include new 

requirements for the providers. OSHA officials said that having these new 

requirements in place for the online training providers will improve the 

providers’ understanding of what is expected of them and help OSHA 

gather additional information on the providers’ performance.

OSHA tracks the number of workers who take the Outreach Training 

courses to measure the reach of the program. OSHA measures the 

results of the Outreach Training Program by setting yearly targets for the 

number of workers trained and uses these data to report its progress in 

meeting its strategic goal of improving workplace safety and health. While 

the agency missed its target for fiscal years 2011 and 2012, it exceeded 

its targets for fiscal years 2013 through 2016 (see fig. 5). OSHA obtains 

information on the number of workers trained from the Education Centers 

and online training providers.

 25 Outreach Training providers can provide the training to workers and employers in the 50 

states, the District of Columbia, the Commonwealth of Puerto Rico, the Virgin Islands, 

American Samoa, Guam, the Commonwealth of the Northern Mariana Islands, Wake 

Island, Outer Continental Shelf Lands defined in the Outer Continental Shelf Lands Act, 

and Johnston Island. OSHA’s Outreach Training Program requirements include 

restrictions on advertising. For example, training providers cannot use Department of 

Labor or OSHA logos in their advertising

OSHA Tracks the Number 

of Workers Trained and 

Requires Some Training 

Providers to Conduct 

Evaluation Activities
Page 22 GAO-17-178 OHSA Training

Figure 5: OSHA Targets for Number of Workers Trained through Its Outreach 

Training Program and Actual Number of Workers Trained, Fiscal Years 2011-2016

OSHA also requires some of the Outreach Training providers to evaluate 

the training they provide using the Kirkpatrick model—a commonly 

accepted model for evaluating training—which is endorsed by the Office 

of Personnel Management in its training evaluation guidance and GAO’s 

training guide.26 The Kirkpatrick model consists of a four-level approach 

for soliciting feedback from training course participants and evaluating the 

impact the training had on individual development, among other things.27

The Education Centers and the online training providers are required to 

report on the first two of those levels (see fig. 6) and are encouraged to 

conduct the other two higher levels of evaluation of the courses they 

 26 United States Office of Personnel Management, Training Evaluation Field Guide: 

Demonstrating the Value of Training at Every Level, (Washington, D.C.: January 2011).

27 Donald L. Kirkpatrick and James D. Kirkpatrick, Evaluating Training Programs: The Four 

Levels, third edition (San Francisco, California: Berrett-Koehler Publishers, Inc. 2012).
Page 23 GAO-17-178 OHSA Training

deliver. Individual Outreach trainers, who provide in-person training to 

workers, are not required to assess the training they deliver.

Figure 6: OSHA’s Requirements for Assessing Outreach Training Compared to 

Kirkpatrick Levels of Evaluation

Note: The Kirkpatrick model is a four-level model for evaluating the effectiveness of training. The 

levels represent w hat the evaluation is expected to accomplish. Donald L. Kirkpatrick and James D. 

Kirkpatrick, Evaluating Training Programs: The Four Levels, third edition (San Francisco, California: 

Berrett-Koehler Publishers, Inc. 2006).

OSHA officials said they decided not to require Outreach trainers 

conducting in-person training to test student knowledge or use student 

evaluations—even though this is how the vast majority of training in the 

program is delivered—because they did not want these activities to take 

away from instructional time. According to OSHA officials, when 

delivering 10- and 30-hour Outreach Training courses in the classroom, 

trainers have the ability to ask questions to encourage student 

participation and use activities to verify that the transfer of learning has 

occurred. However, due to the less interactive nature of the online training 

courses, OSHA determined that the online 10- and 30-hour classes 

require a testing component to ensure the students understand the 

material provided. According to OSHA officials, OSHA also requires 
Page 24 GAO-17-178 OHSA Training

testing for the Education Centers’ train-the-trainer courses to ensure the 

trainers have mastered the course content and are able to effectively 

teach the Outreach Training curriculum to workers.

OSHA has taken some steps to assess the results of some of the 

evaluation information it collects and plans to make greater use of 

evaluation information it collects from the Education Centers in the 

future. For the in-person train-the-trainer courses that the Education 

Centers deliver, OSHA receives test results and copies of student 

evaluations. The Education Centers use a standard student evaluation 

form that can be electronically processed by OSHA. OSHA then 

automatically tabulates the information in the student evaluations and 

returns them to the Education Centers so that they can use them to make 

improvements to their courses. According to OSHA officials, OSHA 

reviewed a sample of the student evaluations and found positive results 

through these reviews. Beginning in fiscal year 2017, OSHA officials said 

they plan to begin assessing the student evaluation results from the trainthe trainer courses as part of the annual appraisal process for Education 

Centers by adding a related performance measure to its expectations for 

the Education Centers. For the online training, OSHA receives test results 

and copies of student evaluations, which ask the students to identify the 

extent to which the training will help them better identify hazards and if 

they had any technical problems accessing the training, among other 

things. According to OSHA officials, they have not used this information to 

assess the results of the Outreach Training Program because the agency 

receives paper copies of the results in different formats, and the agency 

does not have the resources to analyze the information in its current 

format.

We provided a draft of this report to DOL for its review. DOL did not 

provide formal comments and did not have any technical comments.

As agreed with your office, unless you publicly announce the contents of 

this report earlier, we plan no further distribution until 30 days from the 

report date. At that time we will send copies of this report to the 

appropriate congressional committees, the Acting Secretary of Labor, the 

Deputy Assistant Secretary for OSHA, and other interested parties. In 

addition, this report is available at no charge on the GAO website at 

http://www.gao.gov.

Agency Comments
Page 25 GAO-17-178 OHSA Training

Please contact me on (202) 512-7215 or at bawdena@gao.gov if you or 

your staff have any questions about this report. Contact points for our 

Offices of Congressional Relations and Public Affairs may be found on 

the last page of this report. Key contributors to this report are listed in 

appendix I.

Sincerely yours,

Allison Bawden

Acting Director, Education, Workforce,

 and Income Security Issues
Appendix I: GAO Contact and Staff 

Acknowledgments

Page 26 GAO-17-178 OHSA Training

Allison Bawden (202) 512-7215 or bawdena@gao.gov

In addition to the contact named above, Mary Crenshaw (Assistant 

Director), Cathy Roark (Analyst-in-Charge), Hiwotte Amare, Deborah 

Bland, Carol Bray, David Chrisinger, Scott Coleman, Sarah Cornetto, Cliff 

Douglas, Holly Dye, Sharon Hermes, Sheila McCoy, Jonathan McMurray, 

Jean McSween, David Moser, Mimi Nguyen, Stacy Spence, and Bill 

Woods made significant contributions to this report.

Appendix I: GAO Contact and Staff 

Acknowledgments

GAO Contact

Staff 

Acknowledgments

(100594)
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