Recently, OSHA’s Acting Director of Enforcement Programs issued a letter of interpretation in response to the following question: “Are online training programs acceptable for compliance with OSHA’s worker training requirements?”
In short, OSHA remains consistent in its requirement that training must “result in mastery of the training material,” and they also stress that online training must be supplemented by interactive and physical components (such as putting on and removing personal protective equipment).
The full OSHA interpretation is provided here:
Online, self-paced computer-based training can be a valuable part of an effective safety and health training program. However, the use of online training by itself would not be sufficient to satisfy OSHA training requirements unless that training contains interactive and hands-on components.
To be effective, training must result in mastery of the training material (such as, for example, safe work practices or the safe and appropriate use of tools and personal protective equipment). Online training without interactive and hands-on components would not meet this goal.
The opportunity for workers to be able to ask questions of, and receive responses from, a qualified trainer(s), in a timely manner, is critical to effective training. Online training that does not provide workers with this opportunity would not comply with OSHA’s worker training requirements. Training with no interaction, or delayed or limited interaction, between the trainer and trainee, may halt or negatively affect a trainee’s ability to understand and/or retain the training material.
OSHA notes that one way for the employer to give workers this opportunity in the context of a computer-based program is to provide a telephone hotline so that workers will have direct access to a qualified trainer during the conduct of the online training.
Equally important is the provision of sufficient hands-on training because it allows an employee to interact with equipment and tools in the presence of a qualified trainer(s), allows the employee to learn or refresh their skills through experience, and allows the trainer to assess whether the trainees have mastered the proper techniques.
Online training that does not provide workers with hands-on training would not comply with OSHA’s worker training requirements. See letter of interpretation to Ms. Jackie Ward (Nov. 22, 1994). OSHA emphasizes the importance of reviewing specific OSHA standards and related guidance to determine what OSHA requires in specific situations.
At United Alliance, we understand the importance of combining both computer-based training and hands-on training. We continue to provide a variety of options to provide the best safety training experience while complying with OSHA standards.
Take advantage of our Risk Assessment tool and see if your organization is in OSHA compliance.