It’s Cyber-Monday! Maybe you’re online today, buying Christmas gifts for your children, your family, and your friends. The Internet is so convenient! But if that’s where you’re buying health and safety training for your workers, be careful. You could be buying a product that’s missing some pieces, and that can ruin any purchase.
In a Letter of Interpretation issued earlier this year, the Occupational Safety and Health Administration (OSHA) answered a consultant’s questions about computer-based training, and its answer was at odds with the sales pitch offered by many online training providers.
A Complete Package?
Online training providers may promise that you can have a complete training program available using nothing more than an Internet connection and a computer, but OSHA begs to differ. According to the agency, online training alone cannot provide:
Training in physical skills. Physical skills cannot be effectively learned while sitting at a computer, OSHA contends. For example, employees cannot learn to use a fire extinguisher by sitting at a computer screen. Personal protective equipment, too, is difficult to truly master from a keyboard. According to OSHA, these are just two examples of physical skills that can only be learned “by actually practicing them.”
Refresher training for any physical skill also requires hands-on experience, in OSHA’s estimation. In fact, some refresher training may be required based on workers’ demonstrated lack of understanding—more on that below.
Site-specific training. Your online program may be customizable, including maps of your worksite; photos of specific pieces of equipment; drawings, diagrams, and virtual tours; but even if your workers are looking at these things at a computer that’s actually on your site, it doesn’t count as site-specific training. Online training is no substitute for “field work” performed under direct supervision—OSHA offers its hazardous waste operations and emergency response (HAZWOPER) requirements (29 CFR 1910.120) as an example of a standard that requires supervised field work to be included in training. This is something no computer is, as yet, capable of providing.
Evaluation of employee comprehension. Many OSHA standards require employers to verify that employees have understood their training. Sometimes you can do this with a multiple-choice electronically-graded quiz—but not always, especially when skills-based training is involved. The lockout/tagout standard (29 CFR 1910.147), for example, requires employers to verify that workers have mastered both the knowledge and skills required by the rule. Some standards require such verification to be ongoing, as when the respiratory protection standard (29 CFR 1910.134) stipulates the retraining of employees whenever their knowledge or use of the respirator indicates that their understanding is lacking.
You wouldn’t knowingly buy a gift that was missing some of its pieces—you probably even make sure to include batteries. So, don’t buy an online training product that’s missing crucial pieces.