Someone requested OSHA to address the growing field of virtual reality safety and health training. Their letter constitutes OSHA’s interpretation ONLY of the requirements herein, and may not be applicable to any questions not delineated in the original correspondence. Your paraphrased questions and our responses follow.
Question: We have been told online, commercially available, training tools meet OSHA’s training requirements. Can an employer meet OSHA’s training requirements when the training is provided ONLINE ONLY?
Additionally, would the use of virtual reality as the sole medium for providing safety and health training be acceptable to OSHA?
Many OSHA standards require that employees receive training so that they can perform work in a safe and healthful manner. OSHA’s publication, OSHA 2254 provides a list of OSHA training requirements. This publication contains a variety of specific requirements related to employee training as of 2015. Some of the standards listed in OSHA 2254 require “adequate” or “effective” training or instruction. Whether online or virtual reality training methods provide “adequate” or “effective” training may only be determined on a case-by-case basis. Employers need to examine the standards applicable to their workplaces and determine whether the training tools (such as online or virtual reality) they are using advance their employees’ overall comprehension and understanding of workplace hazards.
Effective safety and health training should include hands-on instruction and exercises, which provide employees the opportunity to become familiar with protective measures such as personal protective equipment, and safe workplace practices. For example, the purpose of hands-on training in the donning and doffing of personal protective equipment is two-fold: first, to ensure that workers have an opportunity to learn by experience and second, to assess whether workers have learned to use the protective gear competently.
In some instances, effective training must also provide an opportunity for interactive questions and answers. For example, 29 CFR § 1910.1030(g)(2)(vii)(N) (the Bloodborne Pathogens standard) requires “[a]n opportunity for interactive questions and answers with the person conducting the training session.” When training is provided online or in a virtual reality environment, this requirement may not be met if such an opportunity is not made available.
Additionally, some OSHA standards, such as the Hazardous Waste Operations and Emergency Response (HAZWOPER) standard, 29 CFR §1910.120, and electric power generation, transmission, and distribution, 29 CFR §1910.269, require site and/or job-specific training. Sole reliance on online or virtual reality-based training programs may not provide such site and/or job-specific training. Therefore, the adequacy and effectiveness of safety and health training provided by an employer to his or her employees may only be determined based on the facts of each particular case.