Training and testing knowledge on labor protection

To figure out how to conduct training and organize a test of knowledge of labor protection requirements, two documents that entered into force on September 1, 2022 will help:

Decree of the Government of the Russian Federation of December 24, 2021 No. 2464,
Decree of the Government of the Russian Federation of December 16, 2021 No. 2334.
Order No. 2464 expanded the list of types of training. The complete list looks like this:

labor protection briefing;
on-the-job training;
first aid training for victims;
training in the use of personal protective equipment (PPE) - new;
training in labor protection, including training in safe methods and techniques for performing work, at the employer or in organizations providing services for conducting labor protection training.
For violation of the requirements of the training procedure, they will be held liable under Part 3 of Art. 5.27.1 of the Code of Administrative Offenses of the Russian Federation. The wording of this part of the article makes it possible to prosecute and impose a fine for one untrained employee in the amount of up to 130,000 rubles.

Labor protection briefings

From September 1, 2022, employers are required to carry out:

introductory briefing on labor protection;
briefings on labor protection at the workplace;
target briefing on labor protection.
Induction training
You must complete an introductory briefing:

newly hired employees, as well as seconded from another organization or structural unit;
persons undergoing industrial practice.
The program should be developed on the basis of an indicative list of topics (Appendix No. 1 to the Procedure), taking into account the specifics of the organization's activities. Employees should be instructed by a labor protection specialist or other authorized employee of the organization.

Workplace safety briefings
The rules distinguish primary, repeated and unscheduled briefings on labor protection:

Type of briefing

Who passes and in what cases

Periodicity

Primary

All employees of the organization.
Persons undergoing industrial practice
One time when applying for a job

Repeated

Employees who have completed initial training

At least once every 6 months, unless otherwise provided by the current rules

unscheduled

Employees in the following situations:

the order of operation of equipment, the use of raw materials and materials, technological processes that affect labor safety have been changed;
the job responsibilities of employees related to production have changed, affecting labor safety;
state regulatory legal acts have changed containing labor protection requirements affecting the labor functions of an employee;
local regulations affecting labor protection requirements have changed;
at the workplace, within the framework of the SOUT and the assessment of pro-risks, production factors and sources of danger that threaten the life and health of workers have been identified;
GIT officials established violations of labor protection and put forward such a requirement;
there was an accident or an accident at work;
there was a break in work longer than 60 calendar days;
the decision was made by the employer
As these circumstances arise

You may not conduct initial and repeated briefings if the optimal or permissible class of working conditions is established for the workplaces of individual employees and, in addition to office and household appliances, they do not use other production equipment.

Do not forget to approve the list of professions and positions exempted from employee briefing, and include information on safe methods and techniques for performing work in the introductory briefing on labor protection.
Targeted coaching
This type of briefing is included in a separate form of training. It needs to be done:

before performing work that is carried out under the continuous supervision of the employer, as well as work of increased danger, including those for which, in accordance with regulatory legal acts, a work permit and other administrative documents are required;
before performing work at high-risk facilities, including directly on the carriageway of roads or railways, related to the direct duties of the employee;
before performing work that is not related to the main technological process and not provided for by job or production instructions, including outside the workshop, site;
before loading and unloading works, works on cleaning of territories, works on the carriageway of roads and on railway tracks;
before performing work aimed at eliminating the consequences of emergency situations;
in other cases established by the employer.
Labor protection training
Who is being trained
Order No. 2464 clarifies the categories of employees who must undergo training:

the employer or the head of the organization, his deputies, who are responsible for labor protection;
heads of structural divisions and their deputies;
specialists of structural divisions;
labor protection specialists;
workers of working professions;
members of the knowledge testing commissions responsible for briefings and training;
members of labor protection commissions, authorized representatives of trade unions and other representative bodies.
Do not forget that there are employees who should only study at third-party training centers. Check that it is included in the register of training organizations accredited by the Ministry of Labor of Russia.

These categories of employees include:

heads of organizations and its branches;
chairman and members of commissions to test knowledge of labor protection requirements;
labor protection specialists responsible for briefings and training, members of labor protection commissions, authorized representatives of trade unions;
employees of micro-enterprises responsible for checking knowledge of labor protection requirements.
Please note: heads of structural divisions must also be trained in training centers. From September 1, an employee who conducts initial and repeated briefings on labor protection (in branches, these are most often their heads) must be trained at the training center.

Appendix No. 4 to the Procedure establishes the minimum number of employees who need to be sent for training to a third-party organization. It is determined taking into account the average headcount and risk category of the organization.

How to create training programs
Natalia Gerasimenko

Natalya Gerasimenko, Head of the Examination Center for NOCs in the field of labor safety, social protection and employment of the population, Moscow, comments

Order No. 2464 clearly established what the training program should include: information on the topics of theoretical and practical classes, forms of training and testing knowledge of labor protection requirements, as well as the number of hours allotted for studying each topic, performing practical exercises and testing knowledge of the requirements labor protection.

Each program should include practical exercises that will help to form the skills and abilities to perform work safely, using technical means and visual aids. The minimum volume is at least 25% of the total number of teaching hours.

The question arises, will it be possible to study remotely? Yes, if the training center or the employer can organize the practice with the help of technical aids and visual aids.
Depending on the category of employees, training centers and employers conduct:

Training on general issues and functioning of the labor protection management system,
16 ac. hours;
Training on safe methods and techniques for performing work in the interaction of harmful and hazardous production factors, hazards identified in the framework of the SUT and the OPR, 16 ac. hours;
Training in safe methods and techniques for performing high-risk work, which are subject to additional requirements in accordance with state regulations, 16 ac. hours.
Approximate lists of topics for each of the programs are indicated in Appendix No. 3 to Procedure No. 2464.

If an employee needs to study several programs, their total duration is summed up.

Programs need to be updated:

upon entry into force of regulatory legal acts containing state requirements for labor protection;
when commissioning a new type of equipment, tools and fixtures, introducing new technological processes, raw materials and materials that require additional knowledge;
at the request of GIT officials, for example, during an inspection;
in the event of a change in the job responsibilities of employees directly related to production activities.
If you encounter one of these grounds, update the program and act accordingly in the future.

How often to train
Order No. 2464 approved the following frequency:

Type of training

Periodicity

Scheduled training in labor protection

At least once every three years

Training in safe methods and techniques for performing high-risk work

According to the regulatory legal acts for specific types of work or at least once a year

Training for newly hired or transferred to another job

Within the terms established by the employer, but no later than 60 calendar days after the conclusion of an employment contract or transfer to another job.

If an individual entrepreneur does not have employees, these requirements do not apply to him. But if an individual entrepreneur plans to hire staff, he must first undergo unscheduled training himself and only then conclude an employment contract. Further, the entrepreneur learns at regular intervals.

What to do with the training already completed
Larisa Kocherova

Larisa Kocherova, expert practitioner in the field of labor protection and ecology, lecturer at Kontur.Schools, external expert and participant in scientific and practical events of the All-Russian Research Institute of Labor, member of the working groups of the Ministry of Labor, Rostrud and Rosaccreditation

The training that your employees completed at the training center or at the enterprise itself before Order No. 2464 came into force is valid until the certificates themselves expire. You will have to organize the next training or planned training within the time limits established by the local document for new programs.

Workplace internships
The internship is mandatory for employees who are employed in high-risk jobs, or by decision of the employer. Also, an internship is carried out if it is expressly stated in the legislation, for example, for drivers who transport passengers and goods (guiding document of the Ministry of Autotrans dated 01/20/1986 No. RD-200-RSFSR-12-0071-86-12). If there are no such employees, the internship is not mandatory, but it is possible if the manager approves it in the LNA.

Only those employees who have successfully completed the briefing and training in labor protection are allowed to the internship at the workplace.

What to consider:

Approve the list of professions and positions of employees who need to undergo an internship. Include in it those whose work is associated with increased danger.
Draw up and approve the internship program, terms and procedure. Please note that the duration of the internship must be at least two shifts.
In the regulation on the SUOT or other LNA, write down how you will select mentors and record the results of the internship.
First aid training
This form of training includes the development of knowledge, skills and abilities that will allow employees to provide assistance to victims before the arrival of doctors in case of accidents at work, injuries, poisoning and other conditions that threaten their life and health. The minimum duration is 8 hours. Programs must contain at least 50% of the total number of hours of practical training.

Such training must:

employees responsible for briefings on labor protection, the program of which includes issues of providing first aid to victims;
workers of working professions;
drivers;
persons obliged to provide first aid in accordance with the requirements of the legal acts;
employees whose competencies are required by regulatory authorities and OTs to be able to provide first aid;
chairman and members of commissions for testing knowledge of labor protection requirements on first aid;
persons providing training in first aid to victims;
labor protection specialists, members of commissions, etc.
When you create a list of professions and positions for which you need to organize first aid training, check yourself against this list so as not to miss the right category.

Employees can be trained at a training center or within the organization with the involvement of staff members or other professionals with appropriate training in first aid.

Important! If you organize in-house training, remember that from September 1, the trainer must have training in the first aid teacher training program.
You must complete training at a third-party training center:

chairman and members of commissions for knowledge testing;
persons conducting first aid training;
labor protection specialists.
Frequency of training:

for all categories - at least once every three years;
for newly hired, as well as transferred to another job - within the time period established by the employer, but no later than 60 calendar days after the conclusion of an employment contract or transfer to another job.
The results of the knowledge test are documented in a protocol. If it passes simultaneously through several programs, you can make a general protocol.

Training on the use of personal protective equipment
The training concerns those who use personal protective equipment (PPE) requiring practical skills. The list of such PPE is approved by the employer.

If employees use tools that do not require practical skills to use, the employer can simply teach employees how to check the performance and serviceability of PPE. This can be done during the briefing at the workplace.

The frequency of PPE training is the same as for first aid training.

Checking knowledge on labor protection
You can organize a knowledge test in the training center or on your own. In the second case, the employer creates a commission to test knowledge. Composition - at least three people. The commission may include heads and specialists of structural divisions, heads and specialists of labor protection services, persons conducting labor protection training.

If an employee has not passed the knowledge test, he cannot be allowed to work independently. He is obliged to re-pass the test within 30 calendar days from the date of the first attempt.

The results of testing knowledge of labor protection requirements at the training center and with the employer are documented in a protocol on paper or in electronic form using an electronic signature.

Please note: it is the protocol that plays the main role in confirming training in the relevant programs. Whether or not to issue a certificate to a trainee, the training center or the employer organizing internal training will decide on their own.
The knowledge test protocol states:

full name of the training center or employer;
date and number of the order of the training center or employer on the creation of a commission for knowledge testing;
Full name of the chairman, his deputy and members of the commission;
name and duration of training programs;
Full name, profession, place of work of the person who passed the test of knowledge of labor protection requirements;
the result of testing knowledge of labor protection requirements;
registration number of the entry on checking knowledge of labor protection requirements in the register of persons trained at the training center and with employers.
The registry has not yet been created, this requirement will affect employers and training centers only in 2023.