OSHA sent new compliance directives to their own field people who do site compliance. Those directives contain this type of language:

Failure to train on hazards should be cited. The employees must be provided the training prior to exposure to the hazard. - CFR 1910.1020 says training is required before working in the hazard, and the employer is to provide additional info on the exposure annually thereafter. Do you have your required training?

Ask the employer whether they trained the employees or relied on a third party trainer. If a third-party trainer was used, ask how the employer determined that the training meets the standard. Was the trainer qualified or authorized relating to the subject or hazards?

Did a competent person identify potentially hazardous conditions, which will require training or control strategies?

Did the employer verify that a workplace hazard assessment was performed and does the employer have a written certification that identifies the workplace, person certifying the evaluation, and is it up to date?

Some subparts do not include a testing requirement per say. However, an effective training program necessarily involves some means of determining whether the instruction was completely understood. Ask the employer how it makes this determination. (This can be done in variety of ways; such as formal oral, or written tests does the trainer have training certifications on file?) Also, ask employees about their training. - OSHA will if they inspect your site!

1910.268 (c) - Classroom on the Job
Classroom instruction with a qualified instructor* is mandated by OSHA. OSHA CFR 1910.268 (c) state in part: "Where training is required, it shall consist of on-the-job training or classroom-type training or a combination of both. The employer shall certify the employees have been trained by preparing a certification record which includes the identity of the person trained, the signature of the employer or the person that conducted the training, and the date the training was completed."

*QUALIFIED TRAINER - certified by a competent & qualified person to be able to adequately train, educate, & monitor the company safety program. A qualified person is one who, by possession of recognized degree, certificate, or professional standing, or who by extensive knowledge, training, experience, has successfully demonstrated their ability to solve or resolve problems relating to the subject matter, the work or the project.