OSHA has issued a letter of concern to an organization regarding their 40-hour “HAZWOPER Hands-On Simulator®” on-line training program. OSHA states…As always, the use of interactive and video training programs as a part of an employer’s overall HAZWOPER training program is acceptable. However, an employer may not rely solely on the use of an interactive or video training program to be in compliance with the 40- or 24-hour HAZWOPER training requirements. As was stated in our July 2 letter, “OSHA expects, as part of the 40-hour (or 24-hour) training requirement, that a trainee be able to don, doff, touch, feel, and otherwise manipulate a particular piece of personal protective equipment that an employer of a specific site may require or provide to protect their employees to prevent injury or illness.” Therefore, if the “HAZWOPER Hands-on Simulator®” is used as part of an employer’s overall 40 or 24-hour HAZWOPER training program, in addition to ensuring that the trainee don, doff, and otherwise manipulate the particular piece(s) of personal protective equipment being used at a specific site, its use would be acceptable.
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