The 2026 Training Audit: Mandatory Annual Refreshers

Happy New Year! Let’s Build Smart & Build Safe in 2026. While others are making resolutions they’ll likely break, we are setting a foundation that protects lives this year.

Today, we are auditing Annual Required Training. OSHA mandates several standards that require a "refresher," an annual fit test, or a periodic review of procedures. If these aren’t on your Q1 calendar, you’re already behind.

The "Must-Haves" for 2026

Many companies treat these as "one and done" events. In construction, that's a dangerous mistake. Here are the core annual requirements:

• Respiratory Protection (1910.134): This is the most strict. If your crew wears respirators (even N95s if required by the company), they must have an annual fit test and annual training. You cannot skip this; lungs don't get a "grace period."

• Bloodborne Pathogens (1910.1030): If your team is designated as first-aid responders, they must have annual training. This covers disposal and exposure protocols for your active sites.

• Lockout/Tagout (1910.147): OSHA requires an annual periodic inspection of your energy control procedures. You must verify that your "Authorized" employees understand and are following the specific LOTO steps for your machinery. This should also be covered with employees that are not “Authorized” as they may find themselves in a situation that requires LOTO.

• Fire Extinguishers (1910.157): If you provide extinguishers and expect employees to use them, you must provide an educational program annually to familiarize them with the principles of fire extinguisher use.

The Construction Refresher: Fall Protection & HazCom

While OSHA 1926.503 (Fall Protection) and 1910.1200 (Hazard Communication) don’t explicitly use the word "annual" for every worker, they require retraining whenever there are changes in the workplace, changes in equipment, or evidence of worker inadequacy.

The Full Brim Standard: In high-turnover industries like construction, "Annual" is the only safe frequency. If a worker hasn't reviewed their Fall Protection plan or the SDS for a new solvent in 12 months, their proficiency has likely dropped.

The Skeptic’s Corner: Attendance vs. Competence

Here is the reality check: A signature on a sign-in sheet does not mean your crew is safe. * Stop "Pencil-Whipping": If your training consists of a 10-minute video while people check their phones, you are just managing liability, not risk.

• Verify the Skill: For Fall Protection and LOTO, don't just talk. Have the worker demonstrate a proper harness fit or a successful lockout. If they can't do it in the trailer, they won't do it on the site.

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-The Safety Man