Edward T, I do not doubt this. I couldn't locate this exact OSHA Interpretation. But as a Dealer Principle, I keep records of all of my Training. But I do not control it after the training. It's the customers responsibility to keep up with their operator's and when they are due to go through the training again to stay in compliance. It's also their responsibility to police their operator's on near misses or if they have to have refresher training due to an incident. But if OSHA comes in and request when someone has last been trained, I can show proof in my records, but the customer has the operator's workbook of the class he had taken. I'm not sure if this is whaTt the original question really was. The gentleman that ask it is not a customer, but is from a training organization.