OSH Training in Ukrainian: Valid Records for PIP

You've got Ukrainian lads on your site. Hard-working, switched on - they just catch about every third word in Polish. And now the hundred-point question: how do you run their OSH (occupational safety and health, in Polish BHP) training so the paperwork actually holds up, instead of just sitting in a folder for show? Because a training session run in Polish for someone who doesn't understand Polish is, formally speaking, a piece of scrap paper. An inspector will spot it in five minutes. In this article I'll show you step by step how to sort it out, who can deliver the instruction and how to document the whole thing so it hangs together. And ready-made OSH training records in Polish and Ukrainian versions are in our packages - you sign and carry on.

Key points at a glance

• OSH training in a language the worker doesn't understand is formally invalid - as if it never happened.
• A PIP (Polish Labour Inspectorate) inspector can check whether the worker actually understood the training - including through a remote conversation.
• A worker from Ukraine needs general and job-specific instruction in a language they understand - Ukrainian materials, an interpreter or a bilingual instructor.
• An OSH training record in Ukrainian, signed by the worker, is your proof that you did it properly.
• You - the employer, not the worker - are responsible for the language barrier and the consequences of invalid training.

Why training in Polish for a Ukrainian worker is invalid

The logic is simple. OSH training has one goal: so the worker knows how not to get killed and not to injure themselves or a colleague. How are they meant to know that if they don't understand what you're telling them? The regulations catch this head-on.

The Regulation of the Minister of the Economy and Labour of 27 July 2004 on OSH training states clearly: training must be comprehensible to the participant and adapted to their job. "Comprehensible" is not decoration. If a worker sits there nodding, because they don't want to look stupid, but doesn't get half of it - the training hasn't served its purpose. Formally it exists, in reality it doesn't.

On top of that comes Article 237(3) of the Labour Code: you must not allow a worker to start work if they don't have sufficient knowledge of OSH rules and regulations. "Sufficient knowledge" in a language the person doesn't understand is impossible. So you're letting them work without valid training. And that's on your head.

The inspector will check this - and more thoroughly than you think

There was a time when an inspector looked at the signature on the record and moved on. Today it's different. PIP increasingly verifies whether the training made sense, not just whether the paper existed. With a Ukrainian worker they can simply have a chat - ask what they do, how they'd behave near a given machine, where the emergency stop is.

And here's where it gets interesting, because the conversation can be remote. The inspector phones or connects by video, sometimes with an interpreter. If the worker can't state the basics, and on the record you've got a signature for training "completed" in Polish - you've got a problem. Because it's plain to see that the training was a fiction.

From 8 July 2026 the PIP reform comes into force. The Inspectorate gets stronger tools and more scope to react on the spot. This is not the moment to keep your documentation "roughly right". It's the moment to have it clean.

General instruction and job-specific instruction - two different beasts

Every new worker goes through initial training, and it splits into two parts. They're easy to confuse, so let's break them down.

General instruction

These are the basics. General OSH rules in the company, regulations, first-aid rules, how to behave in a fire, where the evacuation routes are. It's delivered by an OSH service employee or a person the employer has entrusted with those duties. For a Ukrainian worker: materials in Ukrainian or with an interpreter alongside.

Job-specific instruction

This is the concrete stuff for a given job. You show how to safely operate that particular saw, how to secure an excavation, how to walk on scaffolding, what protective equipment to use. This is where the worker learns what could realistically kill them on this site. And this is the most important part - and often the one done most sloppily.

Who can deliver job-specific instruction

This is the question half of firms trip up on. Job-specific instruction is not delivered by an "outside OSH person". It's delivered by the person supervising the workers - that is, you as the foreman, gang leader or site manager - provided you hold current OSH training for people supervising workers.

That makes sense. Who best shows how to do the job safely on a given post? The person who knows that job inside out. But watch out: if your training for supervisors has expired, formally you can't deliver the instruction. And the whole chain falls apart. Check the dates on your own training before you start training others.

With a Ukrainian worker there's an added language layer. If you, the foreman, can't communicate with the worker, you've got two paths: an interpreter during the instruction, or a bilingual instructor who runs it in Ukrainian. Materials and instructions must also be in a version the worker understands.

Workplace instructions - comprehensible, not just in Polish

Here the topic of instructions comes back. The Regulation of the Minister of Labour and Social Policy of 26 September 1997 on general OSH regulations requires OSH instructions to be comprehensible to workers. That word again - comprehensible.

If you've got an instruction by the machine only in Polish, and a Ukrainian worker operates it, then formally that instruction doesn't exist for them. That's why workplace instructions - for operating tools, for working at height, for working in an excavation - should also be in a Ukrainian version. You hang the two versions side by side and it's sorted. For the details of which documents are essential, take a look at our post on OSH documentation for a worker from Ukraine.

The training record in Ukrainian - your proof

All that work has no value if there's no trace on paper. The initial OSH training record is the document that confirms the training took place, who ran it and when. For a Ukrainian worker the record should be bilingual or in a Ukrainian version - so the worker signs something they understand.

This isn't a formality for formality's sake. A signature under a record whose content the worker understands is a signal to the inspector: here the training was genuine, not just ticked off. If the inspector asks the worker and they can say what they were taught - you've got a consistent whole. The paper matches reality.

On the record the following must agree: date, name of the trainer, type of instruction (general and job-specific separately) and signatures. One missing element and the record loses its evidential value.

The responsibility falls on you, not the worker

There's no mercy here. It's the employer who is responsible for the worker being trained and understanding the OSH rules. Not the worker for "not understanding". You, for letting them work without comprehensible training.

If something happens on site and it turns out the training was in Polish for a person who doesn't know Polish - that's your problem when fault is being established. A fine from the inspector is one thing. A case after an accident is a completely different weight. The language barrier doesn't take responsibility off you. It increases it, because it was you who was meant to solve it.

How it works in practice - step by step

Here's how you handle it calmly, without the nerves during an inspection:

1. Prepare materials in Ukrainian. The programme for general and job-specific instruction, workplace instructions, the training record - all in a version the worker will understand.
2. Check your own supervisor training. Before you deliver job-specific instruction, make sure you hold current OSH training for people supervising workers.
3. Deliver the general instruction. OSH basics, first aid, evacuation. In Ukrainian or with an interpreter.
4. Deliver the job-specific instruction. Specific post, specific hazards, specific machines. Show, don't just tell. Have the worker demonstrate themselves that they've got it.
5. Fill in and sign the training record in Ukrainian. Date, trainer, type of instruction, signatures of both parties.
6. Hang the instructions at the workstations. In Ukrainian, in a visible spot by the machine or workstation.
7. Keep the full set in the worker's file. So that during an inspection you can pull everything out in a minute.

That's it. Nothing complicated once you've got the materials ready. The whole difficulty lies in not doing it in Polish "because it's quicker". Because quicker now means a problem later.

Have it ready - the FULL package with Ukrainian versions

You don't have to bang this out from scratch or hunt down a translator for every document. At BudoReady you've got ready-made OSH documentation packages for micro construction firms under PKD 43 (Polish business activity code) - in Polish and Ukrainian.

The FULL package for 749 zł is the complete set that solves exactly this problem: you get every document in a Polish and a Ukrainian version. Training records, workplace instructions, instruction programmes - all bilingual, ready to fill in and sign. You download, complete the details, sign with the worker and you've got documentation that holds up to the law.

For comparison: STARTER for 299 zł is the basic set, STANDARD for 449 zł adds training, and FULL for 749 zł throws in a Ukrainian version of every document - that is, what you actually need with a Ukrainian crew. The promotion runs until 7 July 2026, and the PIP reform comes into force the day after, on 8 July. There won't be a better moment to have your paperwork in order.

See BudoReady packages and choose FULL with Ukrainian versions →

This article is informational and does not replace advice from an OSH specialist or an analysis of the current legal position in your situation. Document templates require individual adaptation to the realities of your company and specific job posts, and the current legal position is worth verifying as of the date of use.