A job-based OSH training matrix: identifying gaps and managing renewals in Spain
A folder of certificates shows which courses were completed, but it does not answer the main question: does each person have the training needed for the tasks they perform today? Answering requires links between jobs, risks, competence and operational changes. That is the purpose of a job-based OSH training matrix.
The matrix should reveal needs and decisions. If it only colours documents according to dates, it can mark someone as “complete” after their job changes or label a course “expired” without a basis for that deadline.
Start with the work actually performed
Article 19 of Spain’s Law 31/1995 (in Spanish) connects preventive training with the job, changes in duties, technology and equipment, and evolving risks. It does not establish one universal expiry period for all OSH training. Reviews should reflect applicable requirements and specific needs.
Use the risk assessment and actual tasks to define competence needs. Distinguish workers who share a job title but perform different activities. “Maintenance”, for example, can cover tasks involving very different equipment, environments and procedures.
Define fields that support decisions
A practical matrix can contain the individual, job, task, requirement, basis, planned training, evidence and review status. Identify who validates whether the training content meets the need. A course title alone does not establish that match.
| Field | Purpose |
|---|---|
| Task and risk | Explain why a competence is required. |
| Content and practice | Describe what the person needs to learn and demonstrate. |
| Evidence | Supports review of attendance, content and the check performed. |
| Review trigger | Identifies a change, observed need or applicable requirement. |
| Owner | Assigns scheduling and result validation. |
The entry on OSH training expands the framework. In software, these fields should reveal gaps by task and site as well as provide access to individual history.
Distinguish outstanding training from outstanding competence
Attending a session and applying a procedure correctly are different checks. Where the task requires it, plan an appropriate practical verification and record the result. Avoid automatically treating an attendance signature as a substitute for every form of competence assessment.
Status can distinguish an identified need, a scheduled activity, completed training and outstanding validation. Adapt the workflow to the learning involved. A straightforward review may be sufficient in some cases, while others need practical observation by a competent person.
An example of a job change
In a fictional company, a worker moves from order preparation to a role with additional warehouse duties. HR records the change and OSH reviews the new activities. The matrix preserves previous training and adds needs arising from the new work.
The owner schedules necessary activities and determines which tasks can be assigned in line with the preventive assessment and applicable requirements. Once training is completed, the content delivered and planned verification are recorded. History explains why the status changed without erasing the person’s previous record.
Give renewal dates a clear basis
For every periodic review, identify its source: a specific rule, applicable collective agreement, equipment conditions, procedure or observed need. Separate document expiry, competence and internal authorisation. If a date reflects an organisational decision, label it accordingly.
Test less obvious situations: someone changes sites, a course covers only part of the required content or a procedure is revised. The matrix should help assess the impact on affected people without indiscriminately restarting all their training.
Include a route for resolving uncertain records. When an imported certificate lacks its programme or practical content, send it for review instead of automatically accepting or rejecting it. Record the reviewer’s decision so the same uncertainty does not reappear at the next review.
Measure coverage that matters operationally
Alongside attendance counts, examine tasks with unmet needs, incomplete validations and job changes awaiting review. Prioritise according to activity and risk. A high overall completion percentage can hide a significant gap in a small team.
Software adoption by supervisors and workers supports communication of these needs; PPE management connects training with equipment use where relevant. In a Sabentis demonstration, test the whole job-change process, from identifying the need to validating evidence.
Checklist before assigning new tasks
Use the matrix to support a specific work assignment. Reviewing it beforehand reveals differences between a course title and the conditions in which the person will actually need to work or respond to a problem.
- Compare the planned task with the task underlying earlier training, including equipment, surroundings, procedures and non-routine situations.
- Check whether the person understands the instructions and learning assessment in the language and format being used.
- Distinguish attendance, demonstrated learning and internal task authorisation, preventing one completion mark from standing for all three.
- Review people covering absences or temporarily changing duties, alongside those moving permanently to a different job.
- Record which gap must be resolved before the assignment and who will communicate that decision to the supervisor organising the work.
Frequently asked questions
Does all OSH training expire after one year?
Spain’s Law 31/1995 sets no universal annual expiry. Review specific rules, applicable collective agreements and needs arising from risks or work changes. In the matrix, distinguish an internal annual review from a statutory or collectively agreed deadline, recording the basis for the date being used.
Can a certificate from another employer cover the current need?
It can provide evidence, but review its content, scope and relationship to the present task. Do not accept or reject it solely because of its issuer or title. Identify which part of the need it covers and which additional information, practice or training must be completed.
Is an online course sufficient for every task?
That depends on the objectives, risks and applicable requirements. Some needs involve practical work or checks not demonstrated by completing digital material. Define what the person must be able to do afterwards and how this will be observed, without automatically equating connection time with competence.
How should training be recorded for someone doing several jobs?
Link needs to tasks and risks while retaining training relevant to more than one function. Avoid duplicating courses unnecessarily and identify outstanding task-specific content. It should be possible to check coverage for each assignment even when the person has a single combined training record.
Legislation and consulted sources
- Law 31/1995, article 19. Spain: preventive training suited to the job and evolving risks. Spanish text.
- Royal Decree 1215/1997, article 5. Spain: information and training for using work equipment, supporting the identification of task-specific needs. Spanish text.
Sources consulted on 6 October 2026.
