The short answer is NO…UNLESS your online training is
- SPECIFIC to your workplace,
- LOTO written program, and
- machine energy isolation procedures
Self-paced, interactive computer-based training can serve as a valuable training tool in the context of an overall training program. However, unless the training program is specific to the servicing that an individual employee will perform, the use of computer-based training alone would not be sufficient to meet the intent of OSHA’s LOTO training requirements. The Agency’s position regarding computer-based training is essentially the same as our policy on using training videos since the two approaches have similar shortcomings. OSHA urges employers to be wary of relying solely on generic, packaged training programs to meet their training requirements. Training must be relevant to the employees’ actual servicing and maintenance work activities. Essential training information will necessarily vary from workplace to workplace, and even from employee to employee within a single workplace, depending on the type and complexity of the energy control procedure and the employee’s duties and responsibilities under the LOTO program. Specifically, training under LOTO includes site-specific elements and, very importantly, it must be tailored to employees’ assigned duties.
In addition, the employer is responsible for ensuring that employees understand the purpose and function of the energy control program and that these employees have the knowledge and skills required to apply the energy control measures safely. In an effective training program, it is important that trainees have the opportunity to ask questions when the material is unfamiliar to them. In a computer-based program, this may be achieved by providing a telephone hotline so trainees can have direct access to a qualified trainer. Equally important is the use of hands-on training and exercises to allow trainees to become familiar with the equipment and safe practices in a non-hazardous setting. Industrial operations, particularly hazardous energy control operations, can involve many complex and potentially hazardous tasks. It is imperative that employees be able to perform such tasks safely. In summary, OSHA believes that computer-based training programs and training videos can be used as part of an effective safety and health training program to satisfy OSHA training requirements if the training as a whole provides employees with the information and knowledge necessary to perform the work safely. CSHOs can determine the adequacy of the training by examining the training program as a whole and by conducting employee interviews to evaluate employee knowledge and understanding.
Source: CPL 02-00-147 The Control of Hazardous Energy – Enforcement Policy and Inspection Procedures