Presumably you've had an objection from the foremen who are worried they may be held to blame if someone is subsequently injured and the training was felt to be deficient.

To some extent that will depend on your current safety culture. Do you partake in witch hunts or try to establish the truth without a blame culture?

Foremen are expected to provide supervision, information and instruction to workers. They have also in the past problably provided training without realising it - imparting pearls of wisdom to new staff members etc.

You are simply formalising what they already do.

To give them some reassurance, as part of the training record can you devise a checklist to ensure all the critical points have been covered? Since you are covering hand tools and basic power tools, something fairly generic along the lines of :-

Have you explained how to :-
- Safely hold the tool.
- Safely change bits, blades, etc.
- Safely apply to the workpiece.
- The importance of clamping the workpiece.
- Ensuring guards, where fitted are working correctly.
- Ensure they have selected the correct tool for the job.
- How to spot defects that affect the safety of the tool.

I suspect you may want to group tool types into their various families so cutting, drilling, surface finishing, impact etc rather than having to repeat the same thing for say "hammer, mallet, bolster etc" under impact tools.

HSE would quite simply state that there is no legal requirement to record this "training" - so why bother?

Sorry I hit the post button before reading my post and also forgot the spell check - which has been playing up lately and not picking up duff words and sometimes picking up good words.

I am sort of with Kate on this.

But lets try and have a go. I suspect that what you were really asking is, could the foreman, as the trainer be liable if someone that he trains is subsequently injured and there is either a criminal investigation, or again I suspect what you're really asking is, if there is a claim for personal injury or damage.

Liability is established on the individual facts of the case and is either accepted (criminal = guilty plea) or 'found' (criminal = found guilty).

I think that is (highly?) unlikely that the trainer is going to be found to be personally liable for a civil claim for damages as this will almost always be the employer who is held vicariously liable.

It is possible I suppose for the trainer to be held criminally liable, but in reality, I suggest that this is again a pretty unlikely scenario unless the trainer was in some way grossly negligent in the training that he gave.

Summary - I suggest that the trainer has little to fear and let's face it OJT has been going on for generations.

Disclaimer - like Kate, I am not quite sure where this fits in, and as has been discussed on here many times, including fairly recently, you can't generally disclaim criminal acts and the remainder of disclaimers are often largely ineffective.