OSHA acknowledges that computer-based training can be a useful component of an overall safety training program. However, OSHA does not consider the use of online training alone to be sufficient to satisfy safety training requirements unless that training contains interactive components. Their position is that to be effective, training must result in a certain level of mastery of the training material and that online training without an interactive component would not meet this goal.
In a recent July 2019 interpretation letter on this topic, OSHA stated that an opportunity for employees to be able to ask questions of, and receive responses from, a qualified trainer in a timely manner is critical for effective training. Online training that does not provide this opportunity would not comply with OSHA’s training requirements. Their position is that 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 noted that one way for the employer to give workers this opportunity in the context of computer-based training is to provide a telephone “hotline” so that employees will have direct access to a qualified trainer at the time they are taking the online training.
Certain OSHA standards such as the Bloodborne Pathogens Standard specifically addresses this requirement. This standard states that training must provide an opportunity for interactive questions and answers with the person conducting the training session.
In addition, OSHA has provided consistent interpretation on the training requirements in the Hazardous Waste Operations and Emergency Response (HAZWOPER) Standard. Related to the training hour requirements for the various levels of emergency response personnel, OSHA has stated that the use of computer-based training will not relieve employers of their obligation to ensure that employees receive the minimum required hours of training specified.
OSHA has also noted that their position on the use of safety training videos alone is essentially the same as their policy on the use of computer-based training, since the two approaches have similar shortcomings. OSHA urges employers not to relying solely on generic, “packaged” training programs in meeting their training requirements as site-specific elements should be included, and to the extent possible the training should be tailored to employees’ assigned duties. They also emphasized that if videos are used an interactive component must be provided that allows the opportunity for employees to ask questions of the trainer.
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