 To: Environmental Health and Safety CoordinatorFrom: Sam Celly, BChE MChE JD CSPDate: December 16, 2025Ref: CALIFORNIA ONLY: Training Documentation Requirements Effective January 1, 2026 OverviewWhen an employee leaves a place of employment, the traning records are left behind. Request by an ex-employee for traning records may go unanswered. CA state arrives to the rescue! Beginning January 1, 2026, California is implementing requirements related to employee access to training records. They affect how dealerships record, maintain, and provide access to training programs. Regulatory agencies are also increasing expectations for annual safety training, particularly for operations involving hazardous materials, spill prevention, and environmental compliance. Proactive alignment now will reduce audit risk and improve readiness going into 2026.What Are the Changes in 2026Employers who maintain training or education records must ensure these records include:Employee nameTraining providerDate and duration of trainingCore competencies or subjects covered (e.g., Heat Illness Prevention, Hazmat, Emergency Response, etc.)Certification or qualification issued, if applicable.Celly Services has created an effortless pathway to obtain employee training records.Login to CSI E-Learn portalClick TRAINING RECORDS tab on the left menu.Type employee email or name on the top and Search.Click “Print Certificate” to obtain training certificate. Under the new law, employees have the right to request and receive copies of their training records.Recommended Actions for DealershipsTo prepare, before January 1, 2026, all dealerships should:Enroll employees onto Celly Services’ E-Learn portal for training modules and recordkeeping.Use this excel spreadsheet to enroll employees onto E-Learn.Once completed, email spreadsheet to elearn@cellyservices.comReview current training files for required documentation elements.Standardized training record templates across all departments.Sign-in-sheets on E-Learn will be updated to reflect the 2026 changes.Retain records in an accessible format (digital format recommended via uploading on E-Learn portal).Provide employees with access upon request within required time limits.Update written training policies to reflect these changes.Why This MattersIncreased regulatory scrutiny and audit frequency.Reduced liability exposure during incidentsStrengthened compliance posture for 2026 and beyond.Consistency across dealership locations and departmentsThank you for your attention to this important update.DISCLAIMER: The contents of this newsletter are merely for informational purposes only and are not to be considered as legal advice. Employers must consult their lawyer for legal matters and EPA/OSHA consultants for matters related to Environmental, Health & Safety. The article was authored by Sam Celly of Celly Services, Inc. who has been helping automobile dealers comply with EPA and OSHA regulations since 1987. Sam received his BE (1984) and MS (1986) in Chemical Engineering, followed by a J.D. from Southwestern University School of Law (1997). Our newsletters can be accessed at www.epaoshablog.com. Your comments/questions are always welcome. Please send them to sam@cellyservices.com. |
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