6.09.2023 OHS (BHP)

[Poland] Initial OHS training – remotely or on-site? Ministry of Labor and Social Policy clarifies doubts

The Ministry of Family and Social Policy confirmed the possibility of conducting the general part of the initial occupational health and safety training remotely, i.e., the so-called general instruction. What is the general instruction and for what is it designed? We explain.  

General health and safety instruction remotely? The Ministry of Family confirms  

In a response issued to Dziennik Gazeta Prawna, the Ministry of Family and Social Policy (MRiPS) confirmed that employers may still carry out the general instruction of occupational health and safety training remotely once the state of epidemic emergency has been cancelled. 

Carrying out the general part of the OSH training via electronic communication tools, also after the state of epidemic emergency is lifted, will certainly make it easier to fulfil this obligation, especially for enterprises with high staff turnover. Of course, general instruction must be carried out in accordance with the provisions of the Labor Code and the Regulation on occupational health and safety training.  

Cancellation of the state of epidemic emergency. How to conduct health and safety training?  

On July 1, 2023, the regulation of the Minister of Health of 14June 2023 officially cancelled the state of epidemic emergency in Poland. Therefore, on July 1, the obligation to conduct induction training in stationary form returned, and all periodic training that was scheduled to take place between 14 March 2020 and 30 June 2023 should be carried out by the 180th day from the date of cancellation of the state of epidemic emergency, i.e., until 28 December 2023 at the latest.  

At present, considering the explanations of the Ministry of Labor and Social Policy, it is known that even now after the pandemic, the general part of the OHS training can be carried out remotely, but the second part of the training for employees hired for stationary work should be carried out at the position for which the instructed employee will be employed.  

In the case of people hired to work remotely for administrative and office positions, initial health and safety training can be entirely carried out via electronic means of communication, i.e. remotely. It is worth emphasizing, however, that all remote employees are also subject to periodic health and safety training.  

General instruction. What does this part of the initial OSH training consist of? 

General instruction is nothing more than general OHS initial training, which is one of the two parts of the initial training. Unlike on-the-job training, i.e., training conducted at the workplace, general instruction can be carried out both in stationary and remote form, i.e., by means of electronic communication.  

General instruction is intended to familiarize the hired employee with the health and safety regulations of the Labor Code, with the work regulations and with the principles of first aid and is addressed to:  

  • newly hired employees,  
  • student-apprentices and  
  • vocational schools’ students employed for the purpose of practical vocational training.  

General instruction may be provided by:  

  • employee of the occupational health and safety service,  
  • a person performing the tasks of this service at the employer,  
  • the employer, if he/she performs such tasks himself/herself,  
  • an employee designated by the employer, if he/she has the knowledge and skills to ensure proper implementation of the training program and has a current certificate of completion of the required training in the field of occupational health and safety.  

The time allotted for the general instruction may not be shorter than 135 minutes, and for its implementation appropriate didactic measures should be used, which may include i.e., videos and instruction boards, as well as means used during first aid.  

Finally, it is worth recalling that all OHS training, pursuant to Art. 237 3 § 3 of the Labor Code, take place during working hours and at the expense of the employer. 

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