Web-based training: What's OSHA position?
The agency’s position is outlined in three “letters of interpretation”, the most recent one written to an environmental training firm in October, 1999, by OSHA chief Charles Jeffress. All three letters focus on the issues of hands-on training and trainer availability. Jeffress makes these points:
- OSHA does not approve or endorse specific training programs.
- In general, OSHA encourages the use of hands-on training, even in refresher courses.
- Hands-on training typically involves trainees interacting with equipment and tools in the presence of qualified trainers.
- Specifically focusing on Hazwoper training, employers could decide that hands-on training is unnecessary — if employees’ skill levels are high enough and employees remain competent in their jobs.
- Employers must give trainees the chance to ask questions and receive answers. When web-based or computer-based training used, a telephone hotline or email satisfies OSHA’s requirement, if responses come from a qualified trainer in a timely manner.
In a 1997 response to an inquiry about computer-based training, OSHA stated that “use of computer-based training by itself would not be sufficient to meet the intent of most of OSHA’s training requirements… OSHA urges employers to be wary of relying solely on generic ‘prepackaged’ programs” in any format due to the need for hands-on training and the opportunity to ask questions about unfamiliar material. “It is unlikely that sole reliance on a computer-based training program is likely to achieve these objectives,” according to OSHA.