EHS Management

Cost, Effectiveness and Volume: Can Computer-Based Training Do All Three?

Training is an essential part of any employer’s Environmental Health and Safety (EHS) compliance program, and some Occupational Safety and Health Administration (OSHA) and U.S. Environmental Protection Agency (EPA) standards have extensive training requirements. Employers spend a lot of money and a lot of worker hours fulfilling those requirements—but how can you know you’re getting what you’re paying for? And could you get more for less?

Most employers are trying to find ways to reduce the time and money spent on training programs, while still making sure they keep the company in compliance and safeguard employees. They are also looking for effective ways to provide the necessary training at the lowest cost possible.

What Does ‘Cost-Effective’ Mean?

In the context of training, “cost-effective” means providing solutions to identified needs (compliance, safety, etc.) at a cost that is a good value for the money and that provides training for enough employees.

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All three of these concerns—cost, effectiveness, and volume—must be balanced to deliver a complete training program. Managers who want to increase cost-effectiveness have three options:

  1. Reduce cost while sustaining effectiveness and maintaining volume (cheaper learning).
  2. Improve effectiveness while holding down costs and volume (better learning).
  3. Increase volume (greater number of trainees and amount of access they have to continue training) while sustaining effectiveness and holding costs (more learning).

Progress is made in cost-effectiveness when these options are implemented alone or in combination.

Is Internet/CBT Enough?

Many employers view computer-based training (CBT) as a way to maintain or increase volume while holding down costs. Internet or other CBT programs are usually self-paced and allow users to access a specific topic at will. Access to the topic is established for single or multiple users via a password over a fixed time frame at a fixed fee by the provider. High-quality, Internet-based training programs are most effective when they simulate an activity and verify that learning took place.

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While CBT programs may be obvious “wins” in the volume and cost columns, their effectiveness may be open to question—more, the question of how regulatory agencies like OSHA view their effectiveness matters a great deal.

OSHA has written four interpretation letters to clarify its position on the use of computer- or Internet-based training programs to meet certain safety and health training requirements. Here is a summary of OSHA’s statements:

  • The employer, not the training provider, is ultimately responsible for ensuring that employees receive the proper training to perform their duties.
  • Use of computer- or Internet-based training by itself would not be sufficient to meet the intent of most OSHA training requirements, in particular those of hazardous waste operations and emergency response (HAZWOPER). Employers may use the CBT programs to meet the minimum requirements for the content material of a training course.
  • Trainees must have the opportunity to ask questions in order for training to be effective; a telephone hotline or e-mail satisfies OSHA’s requirement for trainer access if the employee can ask and receive a response from a qualified trainer.
  • OSHA urges employers to be wary of relying solely on generic “packaged” training programs in meeting training requirements.
  • It is possible in some cases to use CBT to meet the 8-hour HAZWOPER annual refresher training requirements (29 CFR 1910.120(e)(8)) provided the training is supplemented by auditing the hands-on performance of work tasks.
  • Employers that use CBT must still meet the minimum duration and type of hands-on or supervised training specified in OSHA requirements.

Tomorrow, we’ll look at other training delivery methods that can be combined with CBT to add flexibility and enhance training effectiveness.