Introduction

After several articles, are we still talking about institutional structure? Yes—because a sound system makes everything that follows much easier!

In the previous articles, “[ISO 45001 Series] Institutional Structure: Responsible Personnel and Organizational Units” and “[ISO 45001 Series] Institutional Structure: Organizational Roles, Responsibilities, and Authorities,” we tried to outline the responsibilities and authorities of people at each level of the organizational management system governed by ISO 45001, giving everyone a basic picture of their place and work within the system.

The problem is that an employee who feels like a small cog in the organization may find it difficult to see the management system’s overall direction and may not understand why policies are decided as they are.

Different jobs can also involve different hazards. Unless they are highly experienced, new workers may have little awareness of the hazards in their work, and a single misstep can sometimes result in an occupational accident.

It is therefore vital to convey information about potential job hazards and the planning and direction of the organization’s occupational safety and health management system to every worker. This is the important function of the “education and training system” discussed in this article.

Why Education and Training Matters: ISO 45001 and Legal Requirements

ISO 45001 Requirements Related to Education and Training

ISO 45001 does not expressly prescribe a separate education and training system. Its “Support” clause, however, contains requirements that are indirectly connected to such a system.

Competence

Under “Support,” ISO 45001 requires an organization to determine the competence needed by workers who affect or can affect its occupational safety and health performance. This includes the knowledge and skills needed to identify work- and workplace-related hazards appropriately and to address occupational safety and health risks. This is the management system’s requirement for worker competence.

Competence is extremely important to workers because it includes the capability to remove themselves from situations presenting imminent and serious danger.

When determining competence, ISO 45001 suggests considering: 1. the education, training, qualifications, and experience required for a job; 2. the work environment; 3. preventive and control measures arising from the risk assessment process; 4. occupational safety and health management system requirements; 5. legal and other requirements; 6. the occupational safety and health policy; 7. the potential consequences of conformity and nonconformity; 8. the value of worker participation in the management system based on workers’ knowledge and skills; 9. duties and responsibilities associated with roles or positions; 10. individual capabilities; and 11. the need to update competence in response to changes in the organization’s context.

After determining the competence required for each type of work, the organization must ensure that workers are competent on the basis of appropriate education, training, or experience. It may also need to take specific actions—such as training, coaching, or reassigning current personnel, or hiring or engaging competent people—and evaluate whether those actions are effective.

Awareness

Workers must be aware of the overall work environment and the occupational safety and health management system. Without that awareness, even a well-designed system may suffer in performance because of human factors and may even create occupational safety and health risks.

ISO 45001 requires worker awareness to include: 1. the occupational safety and health policy and objectives; 2. workers’ contribution to the effectiveness of the management system; 3. the implications and potential consequences of not conforming to management system requirements; 4. incidents and investigation outcomes relevant to workers; 5. hazards, occupational safety and health risks, and actions relevant to workers; and 6. the ability to remove themselves from work situations they consider to present an imminent and serious danger to life or health, together with arrangements protecting them from undue consequences for doing so.

Interested parties other than workers, such as contractors and visitors, must also be aware of the occupational safety and health risks to which they may be exposed.

The competence and awareness requirements under “Support” show that, although the standard does not expressly require an education and training system, training is indispensable—alongside communication—to make workers competent for their jobs and aware of the management system and their work.

The Importance of Education and Training Under ISO 45001 and Taiwanese Law

In the earlier article, “[ISO 45001 Series] Identifying Internal Issues in the Context of the Organization,” I discussed surveying the organization’s workers and work environment. For different job titles and work content, the organization should establish competence requirements and can assess workers’ current competence at the same time.

Job competence includes the knowledge and skills needed to identify work- and workplace-related hazards appropriately and to address occupational safety and health risks. It is therefore critical to preventing occupational accidents and closely connected to occupational safety and health performance. As noted above, ISO 45001 requires the organization to take action to maintain worker competence or to engage competent workers.

Although ISO 45001 does not expressly establish an education and training system, Taiwan’s occupational safety and health legislation in force when this article was first published did expressly regulate such training.

At that time, Article 32 of the Occupational Safety and Health Act required employers to provide workers with safety and health education and training. An employer that failed to do so was subject under Subparagraph 1 of Article 45 to a fine of NT$30,000 to NT$150,000, showing the system’s importance to occupational safety and health management.

Article 33 also required employers to publicize the Act and relevant safety and health provisions. I therefore believe that organizations can incorporate that legal and safety-and-health communication into their education and training systems.

Article 34 further required employers to formulate safety and health work rules together with worker representatives. Because this is among the relatively few provisions of the Act that can lead to penalties for workers, employers can also use the education and training system to explain those work rules.

To maintain worker competence and satisfy occupational safety and health legal requirements, I recommend that organizations establish a systematic education and training system before putting the management system into operation.

A Recommended Framework for the Education and Training System

Despite the importance of education and training, neither the relevant legislation nor ISO 45001 explains in detail how training should be carried out.

I therefore draw on other education and training literature[1] to establish a systematic process for an occupational safety and health management system. Because that literature provides a general introduction to education and training in human resource management rather than occupational safety and health specifically, I adapt its content here to build a training system integrated with the occupational safety and health management system.

A systematic organizational training process mainly has four phases: training needs and analysis, training design and preparation, training delivery, and evaluation of training effectiveness. Each phase is described below.

Training Needs and Analysis

Training needs and analysis can mainly be divided into organizational analysis, task analysis, and person analysis.

Organizational Analysis

In organizational analysis, the organization must consider its occupational safety and health policy when deciding the direction of training, determine how many resources and how much personnel it can devote to training, and explore workers’ support for and attitudes toward training.

Task Analysis

Task analysis identifies the knowledge, skills, and behaviors required to perform a task and uses them to determine what training should strengthen.

Within an occupational safety and health management system, the organization can review and structure the competence requirements for each type of work and job title while surveying workers and the work environment. As ISO 45001 suggests, workers can also help the organization determine the competence needed for each role.

After defining the competence required for each position or role, the organization can ask employees, supervisors, or relevant experts what knowledge and skills the work or position requires. It can then determine the training content. For crane operators, for example, the content may cover crane operation and methods for identifying and avoiding hazards related to the crane and associated machinery.

Hazards identified later through occupational safety and health risk management, risk assessment results, and the organization’s resulting measures can also be incorporated into training for the corresponding job title and work content.

Person Analysis

Person analysis begins by determining whether poor occupational safety and health performance results from insufficient worker knowledge, skill, or ability, or instead from the work environment. Training is needed when the former is the cause; the organization should then identify which workers need it.

Training Design and Preparation

The most important first step in training design and preparation is to help workers understand the competence they should have after completing the training and to set clear objectives toward which they can work.

In addition to instruction by a trainer, the training process can provide necessary hands-on opportunities, such as actual operation of relevant machinery and equipment.

The organization should design corresponding feedback mechanisms to strengthen workers’ willingness to participate and improve training results, and to determine whether trained workers actually meet the required competence—for example, rewarding competent workers or reassigning those who remain unsuitable for a role.

Training Delivery

Training delivery should differ for managerial and non-managerial personnel.

For non-managerial workers, an organization may mainly use one-way instruction such as trainer-led classroom teaching or multimedia online learning, covering topics such as workplace hazard characteristics. It may also use on-the-job training conducted alongside regular work, with supervisors or other workers offering guidance and suggestions as the worker performs ordinary duties.

For managerial personnel, in addition to the forms of instruction just described, the organization can use job rotation or assign senior managers to coach workers in job-related and decision-making skills. A senior head of an occupational safety and health management unit, for example, might guide safety and health personnel in developing an understanding of the management system.

For both managerial and non-managerial personnel, the organization should encourage participation in—or subsidize—occupational safety and health seminars and courses offered by training providers. Increasing workers’ knowledge and skills not only maintains competence but can also improve occupational safety and health performance.

Evaluating Training Effectiveness

The organization must evaluate the effectiveness of the training it provides so the results can inform improvements to the next program or a cost-benefit assessment. Post-test or pre- and post-test designs can be used to assess satisfaction and usefulness, determine whether workers’ knowledge and skills became competent or improved, and examine whether training effectively improved the organization’s occupational safety and health performance.

Legal Requirements for Training Content

In addition to the theory and operational concepts above, Article 32 of the Occupational Safety and Health Act authorized the competent authority to prescribe the Occupational Safety and Health Education and Training Rules. When this article was first published in 2022, training content, categories, eligible personnel, and hours had to follow those Rules. An employer that failed to provide training as required was subject under Subparagraph 1 of Article 45 to a fine of NT$30,000 to NT$150,000. Workers had a duty under then-Paragraph 3 of Article 32 to receive training, and refusal could be punished under Article 46 by a fine of up to NT$3,000.

The 2022 Rules and the Current Rules After the 2026 Amendments

Rules when this article was published in 2022: Article 32 of the Occupational Safety and Health Act then required employers to provide workers with the safety and health education and training necessary for their work and for disaster prevention, and workers were obligated to receive it. The central competent authority separately prescribed the training content and hours, as well as training-unit qualification requirements and management. An employer that violated Paragraph 1 of Article 32 was then subject under Article 45 to a fine of NT$30,000 to NT$150,000; a worker who violated the duty to receive training was then subject under Article 46 to a fine of up to NT$3,000.

The 2026 amendments: Under the Occupational Safety and Health Act amended and promulgated on December 19, 2025, and effective on July 1, 2026, Article 32 added that safety and health education and training must be conducted by the employer or by a training unit—such as an agency or institution, school, or organization—recognized by the central competent authority. It also more fully authorizes the central competent authority to regulate training-unit qualifications, management, audits, recognition, and evaluation. The worker’s duty to receive training remains, but moved from former Paragraph 3 to current Paragraph 4.[2]

Current rules after the amendments: Paragraph 1 of Article 32 still requires employers to provide workers with the safety and health education and training necessary for their work and for disaster prevention. If an employer does not conduct the training itself and instead uses an external training unit, it should confirm that the unit satisfies the central competent authority’s recognition requirements. The training categories, courses, and hours for each type of personnel must still be determined under the Occupational Safety and Health Education and Training Rules in force at the time. Those Rules strengthened recognition, evaluation, and self-management requirements for units recruiting external trainees from January 1, 2026, and were amended again on June 25, 2026. Organizations and workers should verify the latest provisions and qualified training-unit information when arranging or attending training.[3][4]

Old and current penalties: After the new Act took effect on July 1, 2026, an employer that violates Paragraph 1 of Article 32 and fails to correct the violation by the notified deadline is subject under current Article 45 to a fine of NT$30,000 to NT$750,000. Depending on the size and nature of the enterprise or the circumstances of the violation, the competent authority may increase the fine up to one-half above the statutory maximum. A worker who violates the duty to receive training under Paragraph 4 of Article 32 remains subject under current Article 46 to a fine of up to NT$3,000.[2] Application in an actual case still depends on the specific violation, the corrective notice, and the competent authority’s disposition.

Conclusion

An education and training system helps workers meet competence requirements, understand their work and its hazards, and reduce the likelihood of occupational accidents. It also supports ISO 45001’s requirement that workers be aware of the overall work environment and the occupational safety and health management system. Because occupational safety and health law also requires employers to establish training, its importance is self-evident.

Because the relevant requirements do not explain how training should be conducted, this article draws on human resource development theory to construct an education and training system for occupational safety and health management, as a reference for organizations seeking to build such a system.

The next article is also the final article on management-system structure. It will focus on ISO 45001’s communication system and the retention of documented information. See you in the next article! : )

References

[1] 吳秉恩、黃良志、黃家齊、溫金豐、廖文志、韓志翔, 人力資源管理—理論與實務 [Human Resource Management: Theory and Practice], 4th ed., 2017, p. 262. (Chinese).

[2] Ministry of Labor, Taiwan, Occupational Safety and Health Act, amended and promulgated December 19, 2025; effective July 1, 2026.

[3] Ministry of Labor, Taiwan, Occupational Safety and Health Education and Training Rules, amended June 25, 2026.

[4] Occupational Safety and Health Administration, Ministry of Labor, Taiwan, “New Amendments to the Occupational Safety and Health Education and Training Rules Take Effect on January 1, 2026; Training Units Should Strengthen Training Quality and Management to Improve Workers’ Safety and Health Knowledge,” December 16, 2025.