OSHA requirements for small pipeline contractors: what you actually need

Last updated 2026-07-11

Which OSHA standards actually apply to pipeline contractors?

Pipeline contractors live in a regulatory gray zone that trips up a lot of small shops. Short version: you're almost certainly under 29 CFR Part 1926 (OSHA's construction standards) for any field work involving trenching, pipe installation, or tie-ins, and under 29 CFR Part 1910 (general industry) for shop, yard, or maintenance operations. Do contract work at a facility covered by the Process Safety Management standard, and 29 CFR 1910.119 pulls you in too.

OSHA's construction standards cover any work that counts as construction under the OSH Act, and pipeline installation fits that definition every time ^[1]. Here's where it gets messy. If your crews also do inspection, valve maintenance, or above-ground repairs at an operating facility, OSHA may treat that work as general industry. The nature of the task decides which standard applies, not the industry code on your paperwork.

These are the standards small pipeline contractors run into most:

Standard	CFR Citation	What it covers
Excavation and Trenching	29 CFR 1926 Subpart P	Any trench over 5 feet deep, and shallower ones that show instability
Confined Spaces	29 CFR 1926.1201-1213 (construction)	Manholes, vaults, pipe interiors
Hazard Communication	29 CFR 1910.1200	Chemical labeling, SDSs, training
PPE	29 CFR 1926.95-106	Head, eye, foot, hand, fall protection
Lockout/Tagout	29 CFR 1910.147	Energy control during maintenance
Process Safety Management	29 CFR 1910.119	Applies if you do MOC or tie-in work on covered processes
Respiratory Protection	29 CFR 1910.134	Required when atmospheric hazards exist
Recordkeeping	29 CFR 1904	Injury logs, OSHA 300/300A/301 forms

Small contractors sometimes assume being small buys them an exemption. It mostly doesn't. The 1904 recordkeeping exemption for employers with 10 or fewer employees is real ^[2], but it only spares you the routine injury log. Every underlying safety standard still applies.

Do small pipeline contractors have to have written safety programs?

Yes, several of them. OSHA has no single standard demanding one universal safety program, but a stack of individual standards each require their own written document. If you have crews in the field, you almost certainly owe several of these.

Here are the written programs most pipeline contractors are required to keep:

Excavation and Trenching. 29 CFR 1926 Subpart P requires a competent person on-site for any excavation, someone able to spot hazardous conditions. The standard doesn't name a written "excavation program," but OSHA's enforcement practice makes it nearly impossible to prove compliance without one.

Hazard Communication (HazCom). 29 CFR 1910.1200(e) flatly requires a written hazard communication program. Any employer who uses or stores hazardous chemicals, which every pipeline contractor does with lubricants, solvents, cathodic protection materials, and pipe coatings, must have this in writing and available to employees ^[3]. Our guide to hazard communication walks through the structure.

Lockout/Tagout (LOTO). 29 CFR 1910.147(c)(4) requires a written energy control program ^[13]. If your crews work on or near equipment that has to be de-energized before maintenance, this is mandatory. Our lockout tagout guide covers the procedures.

Respiratory Protection. Require employees to wear respirators, and 29 CFR 1910.134(c) requires a written program covering selection, fit testing, medical evaluation, and maintenance.

Confined Space Entry. For construction, 29 CFR 1926.1204 requires a written permit system for permit-required confined spaces. Manholes and below-grade valve vaults qualify all the time.

Emergency Action Plan. Required under 29 CFR 1926.35 for construction employers. The written plan has to cover evacuation routes and procedures.

If that sounds like a pile of paperwork, it is. A small contractor might burn 15 to 30 hours getting these documents right from scratch, or use a tool like SafetyFolio to generate compliant templates in a fraction of the time. Whatever you use, the programs have to match your actual operations. A generic template you never touched won't hold up when an inspector reads it.

What are the excavation and trenching requirements for pipeline work?

Trenching kills people every year, and pipeline contractors dig trenches for a living. Bureau of Labor Statistics data ranks cave-ins among the leading causes of construction fatalities ^[4], which is exactly why OSHA enforces this standard hard.

29 CFR 1926 Subpart P sets the rules. Every excavation needs a competent person, someone who can identify existing and predictable hazards and has the authority to stop work. That's more than a title on a hard hat. Compliance officers ask pointed questions about what training the person actually has.

For trench protection, the standard gives you three choices: slope the walls to a safe angle, shore them, or drop in a trench box (shield). Which one depends on soil type. OSHA's Appendix B to Subpart P sorts soils into Type A, B, or C by stability. Type C (the least stable, including gravel and wet soil) needs a 1.5H:1V slope or full shoring. Type A (hard, cohesive soil with no fissures) allows a 3/4H:1V slope.

A few requirements catch small contractors flat-footed:

• Access and egress. Any trench 4 feet or deeper needs a ladder, ramp, or stairway within 25 feet of workers ^[1].
• Water accumulation. Standing water demands specific precautions before anyone enters.
• Surface encumbrances. Spoil and equipment stay at least 2 feet back from the edge.
• Daily inspections. The competent person inspects before work each day and again after any event (rain, freeze, vibration) that could affect stability.

OSHA cited trenching violations 1,556 times in fiscal year 2023, putting Subpart P in the top 10 most-cited construction standards ^[5]. A willful violation can run $161,323 as of the 2024 penalty adjustments.

What confined space rules apply to pipeline work?

Pipeline work spins up confined space hazards constantly. Manholes, meter vaults, pig launchers, underground valve chambers, and the inside of large-diameter pipe can all qualify as permit-required confined spaces.

For construction, the standard is 29 CFR 1926.1201-1213, which OSHA finalized in 2015. Before that, construction crews defaulted to the general industry rule (29 CFR 1910.146), and some employers still mix up the two.

A space is permit-required if it has one or more of these traits: it contains or could contain a hazardous atmosphere, it holds material that could engulf an entrant, its shape could trap or asphyxiate, or it carries any other recognized serious safety or health hazard ^[6]. Most underground pipeline spaces check at least one box.

For each permit-required space, you need:

1. A written permit system with pre-entry atmospheric testing. 2. An attendant stationed outside the space at all times. 3. A rescue plan, either an on-site retrieval system or a coordinated response with local emergency services. 4. Communication between entrant and attendant. 5. Atmospheric monitoring for oxygen (19.5% to 23.5% acceptable), flammable gases (below 10% of the lower explosive limit), and toxic contaminants.

Natural gas pipelines create methane and oxygen-deficiency hazards. Older systems can throw off hydrogen sulfide. Neither is something you want to find out about after someone climbs in. Test the air before entry, every time. That one isn't negotiable.

When does OSHA's Process Safety Management (PSM) standard apply to pipeline contractors?

This is the standard that blindsides smaller contractors. 29 CFR 1910.119, Process Safety Management, applies to any employer with highly hazardous chemicals at or above threshold quantities. And it reaches contract workers, which is the part people miss.

Under 29 CFR 1910.119(h), employers who bring in contractors to work on or next to covered processes have to make sure those contractors follow the PSM requirements ^[7]. In practice: if you're doing tie-in work, valve replacement, or any modification to a natural gas facility the host employer has classified as a covered process, you carry PSM obligations even if your own yard holds nothing near a threshold quantity.

The PSM obligations that land on contractors:

• Getting the process hazard information before work starts.
• Training workers on the parts of the host's emergency action plan that apply to them.
• Following every safe work practice the host employer sets.
• Telling the host about any hazard you spot or create.

Natural gas by itself doesn't trigger PSM in most pipeline work, because applicability turns on specific listed chemicals and quantities. Flammable liquids stored above 10,000 pounds at one location can trigger it. Crews at natural gas processing plants or NGL facilities often land in PSM territory.

Unsure whether a client's facility is PSM-covered? Ask. A serious operator will tell you straight. If they dodge the question, that tells you something about their safety culture.

What PPE is required for pipeline construction crews?

OSHA's PPE rules for construction sit in 29 CFR 1926 Subpart E, with specifics scattered across several sub-parts. The baseline: the employer has to assess the workplace for hazards, pick the right PPE, and provide it at no cost to employees ^[8].

The written hazard assessment (required under 29 CFR 1926.95(b)) doesn't need to be fancy, but it has to exist and be certified by the employer. No assessment, no documentation, and you're already in violation before anyone even checks whether the gear itself is right.

For typical pipeline field work, the PPE matrix looks like this:

Hazard	Required PPE	Standard
Falling objects, head strike	Hard hat (Class E for electrical proximity)	29 CFR 1926.100
Foot injuries from heavy pipe	Steel- or composite-toed boots	29 CFR 1926.96
Eye injury from cutting, grinding, welding	Safety glasses, face shield, welding hood	29 CFR 1926.102
Hand injury from sharp edges	Cut-resistant gloves	29 CFR 1926.95
Fall from elevation (pipe racks, above-grade work)	Harness and lanyard	29 CFR 1926 Subpart M
Atmospheric hazards in confined spaces	Supplied air or SCBA	29 CFR 1910.134
High-visibility for traffic exposure	ANSI/ISEA 107 Class 2 or 3 vest	23 CFR 634 (MUTCD)

High-visibility clothing for roadway and right-of-way work technically falls under the Federal Highway Administration's Manual on Uniform Traffic Control Devices and state DOT rules, not a direct OSHA PPE standard. OSHA's General Duty Clause fills the gap, and inspectors cite employers who skip it.

PPE training is mandatory. 29 CFR 1926.95(c) requires training on when PPE is needed, which type fits the hazard, and how to put it on, adjust it, and take it off. Document the training. Every time.

What training does OSHA require for pipeline workers?

There's no single OSHA training certificate that covers pipeline work. Requirements come from the specific standards that apply to your operations, and they stack up fast.

Here's the core training your crews likely need, matched to the standard behind each:

• Excavation competent person: required by 29 CFR 1926 Subpart P, with no prescribed hour count. The competent person has to classify soils, spot hazards, and know the protective system options. OSHA's own training materials note competent person courses typically run about 8 hours, though there's no regulatory minimum ^[1].
• Confined space entrant, attendant, and supervisor: 29 CFR 1926.1207 requires each authorized entrant, attendant, and entry supervisor to know their specific duties.
• HazCom: 29 CFR 1910.1200(h) requires training before initial assignment and again when new hazards show up. No hour minimum, but it has to cover the SDS system and reading labels.
• Lockout/Tagout: 29 CFR 1910.147(c)(7) requires training for authorized employees (who perform LOTO) and affected employees (who work where LOTO is used) ^[13].
• Respiratory protection: 29 CFR 1910.134(k) requires training before the respirator is used, repeated annually.
• Forklift/powered industrial truck: if your yard runs forklifts, operators need training under 29 CFR 1910.178. Our article on forklift certification covers what that takes.
• First aid: 29 CFR 1926.50 requires at least one trained person on-site when a hospital isn't within three to four minutes of travel time.

For supervisors and safety leads, an OSHA 30 course is the recognized benchmark, though no regulation requires it. It runs through the major construction hazards in a format that builds real knowledge. Our OSHA training overview breaks down how the credential levels compare.

Keep the records. OSHA doesn't always spell out a retention period, but the common practice is three years, and your records need to show who was trained, on what, by whom, and when.

What are the OSHA recordkeeping requirements for small pipeline contractors?

Recordkeeping under 29 CFR Part 1904 has two layers for small contractors: whether you have to keep an injury and illness log at all, and if you do, what you have to submit electronically.

The 10-employee exemption. Employers with 10 or fewer employees at all times during the previous calendar year get a partial exemption from routine recordkeeping under 29 CFR 1904.1 ^[2]. No OSHA 300 log, no annual summary. But you still report any work-related fatality within 8 hours, and any in-patient hospitalization, amputation, or eye loss within 24 hours. That reporting rule has no size exemption.

The 11-plus requirement. With 11 or more employees, you keep the OSHA 300 log (a running record of recordable injuries and illnesses), a 301 incident report for each recordable event, and the 300A annual summary. The 300A gets posted from February 1 through April 30 each year.

Electronic submission. As of January 1, 2024, establishments with 100 or more employees in high-hazard industries must submit their 300 log data through OSHA's Injury Tracking Application (ITA) by March 2 each year, and NAICS 237120 (oil and gas pipeline construction) is on the list ^[9]. Establishments with 20 to 249 employees in high-hazard industries submit 300A summary data. If your company sits at 20 or more employees, check whether your NAICS code lands you in the high-hazard bucket.

For filing an incident report correctly, the OSHA 301 (or an equivalent state form) captures first aid treatment, whether the worker lost time, and the nature of the injury. Get this right. It decides whether an injury is recordable, which drives your DART rate, which drives your EMR, which drives your insurance premiums and your bid eligibility.

What fines can OSHA impose on a small pipeline contractor?

OSHA's penalties as of 2024 run from $0 for a first-time minor slip up to $161,323 per violation for willful or repeated violations ^[10]. The numbers adjust every year for inflation under the Federal Civil Penalties Inflation Adjustment Act.

Small businesses get a break. Employers with 25 or fewer employees can receive a 60% reduction on most penalties. Employers with 26 to 100 employees get 40%. Those cuts hit the initial penalty, before any settlement talk starts.

The categories:

Violation Type	Max Penalty Per Violation (2024)
Other-than-serious	$16,131
Serious	$16,131
Repeat	$161,323
Willful	$161,323
Failure to abate	$16,131 per day

Inspections of pipeline contractors most often start with fatalities and hospitalizations (which trigger mandatory inspections), employee complaints, and referrals from other agencies. Pipeline work also draws attention from OSHA's National Emphasis Programs on trenching and excavation.

The informal settlement conference is your first shot at cutting penalties after a citation lands. Small employers who show up in good faith, bring an abatement plan, and document financial hardship usually see real reductions. Ignoring a citation is the worst move you can make.

What does OSHA's General Duty Clause mean for pipeline contractors?

Section 5(a)(1) of the OSH Act requires every employer to furnish a workplace "free from recognized hazards that are causing or are likely to cause death or serious physical harm." That's the General Duty Clause, OSHA's catch-all for hazards no specific standard covers.

For pipeline contractors, this matters because some of the industry's worst hazards have no tidy CFR section. A few examples:

• Struck-by hazards from pipe swinging on a crane or excavator bucket.
• Heat illness during summer excavation in southern states.
• Third-party damage from mechanical excavation near existing pipelines.

OSHA runs a heat illness National Emphasis Program aimed at outdoor workers, and pipeline trenching crews in summer heat are exactly the population it targets ^[11]. OSHA has been working on a formal heat standard for years, but the General Duty Clause already lets inspectors cite heat hazards with no specific standard on the books.

The practical takeaway is blunt: if you know a hazard exists, the industry recognizes it as serious, and there's a feasible way to control it, OSHA can cite you for leaving it alone. "There's no standard for that" is not a defense.

How do multi-employer worksite rules affect pipeline contractors?

Pipeline contractors almost always work next to other trades: survey crews, restoration contractors, inspectors, sometimes the utility owner itself. OSHA's multi-employer citation policy (CPL 02-00-124) decides who gets cited when something goes sideways ^[12].

OSHA recognizes four roles on a shared worksite. The creating employer made the hazard. The exposing employer has workers facing it. The correcting employer is responsible for fixing it. The controlling employer supervises overall site safety. You can hold more than one of these at once.

As a pipeline contractor, you're almost always the exposing employer for your own crews. If you're the general contractor, you're also the controlling employer, which puts a duty on you to exercise reasonable care to keep subcontractors from creating hazards.

Here's the classic multi-employer scenario for pipeline work. A subcontractor's crew is excavating, they leave a trench unprotected, and a general contractor's employee gets hurt. OSHA cites both. The sub gets it as the creating employer. The GC gets it as the controlling employer for failing to catch and correct the condition.

The controlling employer's defense is that you had reasonable safety procedures, you communicated them, and you exercised appropriate oversight. Paper trails matter here. Job hazard analyses, documented pre-work safety meetings, and correction notices to subs are your evidence.

How do you build a practical safety program for a small pipeline contractor?

A safety program for a 10-person pipeline crew doesn't need to be a 200-page binder. It needs accuracy, specifics tied to your operations, and evidence that people actually use it.

Start with a hazard inventory. Walk through everything your crews do: digging, pipe handling, welding, working in traffic, entering manholes, running equipment. List each task and its hazards. That list becomes the spine of the whole program.

Then match each significant hazard to the written program OSHA requires for it. Build them one at a time. A hazard communication program for a small crew can run eight pages. An excavation safety plan covering your typical soils and protective systems might run twelve. Don't pad them. Specificity beats length every time.

For a lot of small contractors, the hard part isn't knowing what's required. It's getting the documents written. SafetyFolio's safety program generator asks questions about your operations and produces OSHA-aligned written programs in about 15 minutes each, which is genuinely useful when a two-person office is running field crews.

Once the programs exist, three things make them real: training records proving employees know the contents, a review cycle (annually or after any serious incident), and a clear chain of accountability. Who's the competent person for excavations? Who works confined space attendant duty? Who can stop work? Write those names or roles right into the programs.

Job hazard analyses (JHAs), sometimes called job safety analyses (JSAs), are the daily tool connecting your written programs to real field conditions. A JHA for one trench or one confined space entry takes 10 minutes and creates the documented pre-work review OSHA looks for. Get your crew leads doing one before every significant task, and the habit does more for you than any binder on a shelf.

Frequently asked questions

Does OSHA's 10-employee exemption mean small pipeline contractors don't have to follow safety standards?

No. The 10-employee exemption under 29 CFR 1904.1 only covers routine injury log recordkeeping. It does not exempt you from any substantive safety standard. Trenching, confined space, PPE, HazCom, and every other standard apply to employers of any size. You still must report fatalities within 8 hours and hospitalizations within 24 hours, no matter how many employees you have.

What is a competent person under OSHA's excavation standard, and who can serve in that role?

OSHA's 29 CFR 1926 Subpart P defines a competent person as someone capable of identifying existing and predictable excavation hazards and authorized to take corrective action, including stopping work. There's no required certification or license. The bar is knowledge plus authority. In practice, a foreman or crew lead who has finished a recognized competent person course and understands soil classification typically qualifies.

Do pipeline contractors need OSHA 10 or OSHA 30 cards?

Federal regulation doesn't require the 10-hour or 30-hour cards. But many pipeline owners and general contractors require them by contract, and several states (New York, Massachusetts, Nevada, and others) mandate OSHA 10 cards for certain construction workers by law. An OSHA 30 is the recognized benchmark for supervisors and safety leads. Check your contract requirements and your state's rules.

What atmospheric testing is required before entering a pipeline vault or manhole?

Before entering any permit-required confined space, 29 CFR 1926.1203 and 1204 require atmospheric testing in this order: oxygen concentration (acceptable range 19.5% to 23.5%), flammable gases and vapors (below 10% of the lower explosive limit), then toxic substances. Test before entry and monitor continuously during occupancy. The person testing has to use a calibrated, direct-reading gas monitor.

Can OSHA inspect a pipeline contractor with only 5 employees?

Yes. OSHA can inspect any covered employer regardless of size. The OSH Act covers all private sector employers with one or more employees. Small-employer status can cut penalties if violations turn up, but it gives no immunity from inspection. Inspections start from employee complaints, fatalities, hospitalizations, referrals from other agencies, or planned National Emphasis Program sweeps targeting trenching and excavation.

What pipeline contractor safety violations does OSHA cite most often?

Based on OSHA's most-cited construction standards data, trenching and excavation violations (29 CFR 1926 Subpart P) consistently rank in the top 10. Common specifics include no competent person on-site, no protective system in trenches over 5 feet, inadequate access and egress, and spoil piled within 2 feet of the trench edge. Hazard communication, fall protection, and confined space entry violations also show up often.

Does a pipeline contractor need a written safety program if they have no full-time safety person?

Yes. OSHA's requirement for written programs (HazCom, LOTO, respiratory protection, confined space permits, emergency action plan) doesn't hinge on whether you employ a dedicated safety professional. The programs are required because the hazards exist, not because of company size. The owner or a senior manager can be the responsible party. The programs do have to reflect your actual operations and be available to employees.

What are the penalties for an unprotected trench violation by a small pipeline contractor?

An unprotected trench violation is typically serious, with a maximum penalty of $16,131 per violation as of 2024. Small employers with 25 or fewer employees qualify for a 60% reduction, bringing the typical initial penalty down a lot. But if a worker was injured or OSHA finds the employer knowingly ignored the hazard, it can be classified as willful, with a maximum of $161,323 per violation.

Are pipeline contractors responsible for subcontractors' safety on their job sites?

If you're the controlling employer on a project, OSHA's multi-employer citation policy (CPL 02-00-124) holds you responsible for exercising reasonable care to detect and correct hazards your subcontractors create or face. You don't have to catch every violation, but you need documented safety requirements in contracts, regular site walk-throughs, and a process for fixing hazards when you find them. The standard is reasonable oversight, not perfection.

How long does a small pipeline contractor need to keep safety training records?

OSHA has no single universal retention rule for training records. Specific standards set their own timelines: respiratory protection medical evaluations must be kept for the duration of employment plus 30 years under 29 CFR 1910.1020, LOTO records for the duration of employment, and respirator fit test records until the next test. A practical rule most safety professionals follow is to retain all training documentation for at least three years.

Does OSHA's heat standard apply to outdoor pipeline crews?

As of mid-2025, OSHA's formal heat standard has been proposed but not finalized. The General Duty Clause and the National Emphasis Program on outdoor and indoor heat hazards already give inspectors authority to cite heat-related hazards now. Pipeline crews digging trenches in hot weather sit squarely in scope. Basic controls (water, rest, shade, acclimatization for new workers) are the recognized industry practice OSHA measures against.

What is the OSHA reporting deadline for a pipeline worker hospitalization?

Under 29 CFR 1904.39, any in-patient hospitalization of one or more employees from a work-related incident must be reported to OSHA within 24 hours. A work-related fatality must be reported within 8 hours. You can report by calling the nearest OSHA area office, calling 1-800-321-OSHA, or using OSHA's online reporting portal. These deadlines apply to all employers, regardless of size.

Do pipeline contractors need a Site Safety Plan or just the individual written programs?

Federal OSHA doesn't require a single overarching Site Safety Plan for most pipeline construction (large public works projects and some state-plan states differ). What you need are the individual written programs each applicable standard requires: HazCom, LOTO, confined space, respiratory protection, emergency action plan, and others. Organizing them into one binder or a shared digital folder labeled as your safety program is practical, but the legal requirement is each individual document.

Sources

1. OSHA, 29 CFR 1926 Subpart P - Excavations (construction standards): Pipeline installation qualifies as construction under the OSH Act; trenches 4 feet or deeper require access and egress within 25 feet of workers
2. OSHA, 29 CFR 1904.1 - Purpose and Scope (small employer exemption): Employers with 10 or fewer employees are partially exempt from routine recordkeeping but not from underlying safety standards
3. OSHA, 29 CFR 1910.1200 - Hazard Communication Standard: 29 CFR 1910.1200(e) requires a written hazard communication program for any employer using or storing hazardous chemicals
4. Bureau of Labor Statistics, Census of Fatal Occupational Injuries: Cave-ins and excavation collapses are among the leading causes of construction fatalities annually
5. OSHA, Top 10 Most Frequently Cited Standards FY2023: Trenching violations (29 CFR 1926 Subpart P) were cited 1,556 times in fiscal year 2023, ranking in the top 10 most-cited construction standards
6. OSHA, 29 CFR 1926.1201 - Confined Spaces in Construction: A space is permit-required if it contains or has the potential to contain a hazardous atmosphere, engulfment material, or other recognized serious safety hazard
7. OSHA, 29 CFR 1910.119(h) - Process Safety Management, Contractor Requirements: PSM standard section (h) requires host employers to ensure contract workers performing work on or adjacent to covered processes comply with PSM requirements
8. OSHA, 29 CFR 1926.95 - Personal Protective Equipment, General Requirements: Employer must assess workplace for hazards, select appropriate PPE, and provide it at no cost to employees; written hazard assessment must be certified
9. OSHA, Electronic Recordkeeping Rule (2024 update), Injury Tracking Application: As of January 1 2024, establishments with 100 or more employees in high-hazard industries including NAICS 237120 must submit 300 log data electronically by March 2 each year
10. OSHA, Civil Monetary Penalty Adjustments 2024: Maximum penalty for willful or repeat OSHA violations is $161,323 per violation as of 2024; serious violations maximum is $16,131
11. OSHA, National Emphasis Program on Outdoor and Indoor Heat-Related Hazards (CPL 03-00-024): OSHA's heat NEP targets outdoor construction workers including pipeline trenching crews under General Duty Clause authority
12. OSHA, Multi-Employer Citation Policy (CPL 02-00-124): OSHA's multi-employer citation policy recognizes creating, exposing, correcting, and controlling employers and can cite more than one for the same hazard
13. OSHA, 29 CFR 1910.147 - Control of Hazardous Energy (Lockout/Tagout): 29 CFR 1910.147(c)(4) requires a written energy control program; (c)(7) requires training for authorized and affected employees