If you’re like many employers, you offer some portion of your safety training in an online format. But what does OSHA think about this, and is it adequate to keep you in compliance?
In a letter of interpretation (LOI) from June 2017, OSHA responded to an employer’s question as to whether computer-based training without a hands-on skill component or skill verification satisfied requirements for a number of training standards in general industry and construction. The list included personal protective equipment (PPE), hazard communication, lockout/tagout, fall protection, electrical training, lead, and emergency action plans, among others.
OSHA responded that online training alone would not meet the requirements for these and other training standards. In its response to the employer, OSHA cites a dictionary definition of “train” that refers to making “proficient with special instructions and practice.” A letter of interpretation signed by Thomas Galassi, director of OSHA’s Directorate of Enforcement Programs, explains that the only way physical skills, such as using a fire extinguisher or properly caring for PPE, can be learned is by actually practicing them. Galassi points out that the standards listed do not all require certification of competent performance.
Also, according to the interpretation, an employer cannot meet annual refresher training requirements for the standards above (and others) using only online training. Asked if the employer is required to provide site or company-specific training to comply with any of the listed standards, OSHA responded yes and noted several such instances. For example, hazardous waste operations and emergency response (HAZWOPER) requires the following site-specific provisions:
“General site workers (such as equipment operators, general laborers, and supervisory personnel) engaged in hazardous substance removal or other activities which expose or potentially expose workers to hazardous substances and health hazards shall receive a minimum of 40 hours of instruction off the site, and a minimum of three days actual field experience under the direct supervision of a trained experienced supervisor.”
Several other provisions of the HAZWOPER standard also require site-specific training.
The LOI can be found at https://safety.blr.com/workplace-safety-reference-materials/OSHA-interpretations/safety-administration/workplace-safety-training/Clarification-of-OSHA-training-requirements-via-on/.