Over my career in S&H and Emergency Response, I have seen the proliferation of “on-line” training get out of control in the past 10 years. Seems the sellers have sold the on-line delivery method as the “silver bullet” – the answer to all the training woes within an organization. Heck even OSHA has allowed some of their outreach training to be done on-line. But this summer, OSHA issued an LOI that makes it CLEAR…
… 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.
Question 1: Are online training programs acceptable for compliance with OSHA’s worker training requirements?
Response: 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) (copy enclosed). OSHA emphasizes the importance of reviewing specific OSHA standards and related guidance to determine what OSHA requires in specific situations.