OSHA Computer and Web-Based Training Interpretation Letters

October 11, 1994
Mr. Gerald J. Joy
Health and Safety Director
ICF Kaiser Engineers, Inc.
Environment and Energy Group
Four Gateway Center
Pittsburgh, Pennsylvania 15222-1207

Dear Mr. Joy:

Thank you for your letter of December 29, 1993, forwarded to OSHA's Directorate of Compliance Programs from our Directorate of Technical Support, concerning the Occupational Safety and Health Administration's (OSHA) Hazardous Waste Operations and Emergency Response (HAZWOPER) regulation, 29 CFR 1910.120. Please accept my apology for the delay in this response.

Your question requests clarification on the acceptability of a computer based, self-paced training program for use in meeting the refresher training requirements of the standard. Based on the information you have provided, it is not possible for OSHA to assess the effectiveness of the particular computer-based training program in question. We will address in more general terms the issue of computer-based training before answering your specific question on the refresher training required in paragraph (e)(8) of the standard.

In OSHA's view, self paced, interactive computer-based training can serve as a valuable training tool in the context of an over-all HAZWOPER training program. However, use of computerbased training by itself would not be sufficient to meet the intent of the standard's various training requirements. Our position on this matter is essentially the same as our policy on the use of training videos, as the two approaches have similar shortcomings. OSHA urges employers to be wary of relaying solely on generic "packaged" training programs in meeting their training requirements. Training required under HAZWOPER includes site-specific elements and should also to some degree be tailored to workers' assigned duties.

In order for the training to be effective, trainees must have the opportunity to ask questions. This requirement could be met by providing a telephone hotline so that trainees will have direct access to a qualified trainer. The trainees' mastery of covered knowledge and skills must also be assessed. It is not clear whether "validation of course-work completion" as described in the advertisement you enclosed means that this particular computer-based training program actually assesses whether workers have mastered the covered material.


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Hazardous waste operations can involve many complex and hazardous tasks. It is imperative that employees be able to perform such tasks safely. Thus, auditing of worker performance is required for all types of HAZWOPER training. In the case of refresher training, this requirement for auditing of worker performance could be addressed during periodic safety meetings. Traditional, hands-on training is the preferred method. The purpose of hands-on training, for example in the donning and doffing of personal protective equipment, is two-fold: first, to ensure that workers have an opportunity to learn by experience, and second, to assess whether workers have mastered the necessary skills. The employer may determine that hands-on training is unnecessary for a given refresher course. However, if an employer elects not to use hands-on training in their refresher course, the employer must first assess the employees' skill level, and ensure that workers remain competent in their current and any newly assigned duties.

In conclusion, it is possible in some cases to use computer-based training in meeting the refresher training requirements of 29 CFR 1910.120(e)(8), provided that the computer-based training covers topics relevant to workers' assigned duties and is supplemented by the opportunity to ask questions of a qualified trainer, as well as an assessment of worker skill degredation through auditing of hands-on performance of work tasks. We hope this information is helpful. If you have further questions please feel free to contact the Office of Health Compliance Assistance (202) 693-2190.

Sincerely,
Ruth E. McCully,
Director Office of Health Compliance Assistance

----------------------------------------------------

November 22, 1994
Ms. Jackie H. Ward
ENTERGY Gulf States Utilities
Post Office Box 2951
Beaumont, Texas 77704

Dear Ms. Ward:
Thank you for your letter of September 2, forwarded to the Occupational Safety and Health Administration's (OSHA's) Directorate of Compliance Programs from our Area Office in Baton Rouge, Louisiana, concerning the use of computer-based training to satisfy OSHA training requirements. In your letter, you ask a series of questions requesting clarification on whether the use of computer-based training is sufficient to comply with the minimum training requirements for initial employee training and retraining, in particular with regard to the number of hours of training required. We assume that your primary interest is in the training requirements of OSHA's Hazardous Waste Operations and Emergency Response Standard (HAZWOPER, 29 CFR 1910.120 and 1926.65), although you questions are also relevant to the training requirements of other OSHA standards. Each of the questions in your letter are answered in turn below.

1. What is OSHA's position on computer-based training programs for cognitive training?

In OSHA's view, self-paced, interactive computer-based training can serve as a valuable training tool in the context of an overall training program. However, use of computer-based training by itself would not be sufficient to meet the intent of most of OSHA's training requirements, in particular those of HAZWOPER. Our position on this matter is essentially the same as our policy on the use of training videos, since the two approaches have similar shortcomings. OSHA urges employers to be wary of relying solely on generic, "packaged" training programs in meeting their training requirements. For example, training under HAZWOPER includes site-specific elements and should also, to some degree, be tailored to workers' assigned duties.

Safety and health training involves the presentation of technical material to audiences that typically have not had formal education in technical or scientific disciplines, such as in areas of chemistry or physiology. In an effective training program, it is critical that trainees have the opportunity to ask questions where material is unfamiliar to them. In a computer-based program, this requirements may be providing a telephone hotline so that trainees will have direct access to a qualified trainer.

Equally important is the use of hands-on training and exercises to provide trainees with an opportunity to become familiar with equipment and safe practices in a non-hazardous setting. Many industrial operations, and in particular hazardous waste operations, can involve many complex and hazardous tasks. It is imperative that employees be able to perform such tasks safely. Traditional, hands-on training is the preferred method to ensure that workers are prepared to safely perform these tasks. The purpose of hands-on training, for example in the donning and doffing of personal protective equipment, is two-fold: first, to ensure that workers have an opportunity to learn by experience, and second, to assess whether workers have mastered the necessary skills. It is unlikely that sole reliance on a computer-based training program is likely to achieve these objectives. Thus, OSHA believes that computer-based training programs can be used as part of an effective safety and health training program to satisfy OSHA training requirements, provided that the program is supplemented by the opportunity for trainees to ask questions of a qualified trainer, and provides trainees with sufficient hands-on experience.

2. How will computer-based training be compared to required hour training as set forth in 1910.120?

Where OSHA has specified a required duration represents, in OSHA's view, the minimum amount of training that will be needed for most trainees to acquire the necessary basic skills. For the reasons stated above, OSHA does not believe that the use of computer-based training will, in the majority of cases, enable trainees to achieve competency in substantially less time than the required minimum duration for training. Therefore, the use of computer-based training will not relieve employers of their obligation to ensure that employees receive the minimum require amount of training specified under HAZWOPER and other OSHA standards.

3. Will a computer-based program's outline and development material suffice for conventional training material documentation?

OSHA standards, and HAZWOPER in particular, do not specify the kinds of materials that must be developed and maintained to document that a course meets the minimum requirements for course content. Employers may use whatever documentation is necessary to document the content of a training course.

4. Will computer-based tracking of training competence levels be documentation enough for the training or will a hard copy, signed document be required?

OSHA standards that require training generally contain a requirement for the employer to maintain records of employee training; these records may be kept in any form deemed appropriate by the employer, so long as the records are readily accessible to the employer, employees and their representatives, and to OSHA. However, note that the HAZWOPER standard contains a unique requirement in that employees must be provided a certificate upon the successful completion of initial training; this is best accomplished by the use of hard copy. We hope that this information is helpful. If you have any further questions, please feel free to contact the Office of Health Compliance Assistance at [(202) 693-2190].

Sincerely,
Ruth E. McCully,
Director Office of Health Compliance Assistance

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June 11, 1997

Ms. Anna E. Jolly, JD, CHMM
Circle Safety & Health Consultants, LLC
P.O. Box 29
Gum Spring, VA 23065

Dear Ms. Jolly,

This letter is in response to your letter of May 27th to John Miles regarding the appropriateness of computer-based interactive training programs to satisfy required OSHA training. You expressed particular interest in its use for bloodborne pathogen training. Interactive computer-based training can serve as a valuable training tool in the context of an overall training program. However, use of computer-based training by itself would not be sufficient to meet the intent of most of OSHA's training requirements. Our position on this matter is essentially the same as our policy on the use of training videos, since the two approaches have similar shortcomings. OSHA urges employers to be wary of relying solely on generic "packaged" programs in meeting their training requirements. Training under the bloodborne pathogen standard includes site-specific elements and should also to some degree be tailored to workers' assigned duties. In an effective training program, it is critical that trainees have an opportunity to ask questions where material is unfamiliar to them. In a computer-based program, this requirement may be met by providing a telephone hotline so that trainees will have direct access to a qualified trainer. Equally important is the use of hands-on training and exercises to provide trainees with an opportunity to become familiar with equipment, personal protective equipment, and safe practices (e.g. glove removal) in a non-hazardous setting. It is unlikely that sole reliance on a computer-based training program is likely to achieve these objectives. We hope that this information is helpful. If you have any further questions, please feel free to contact Craig Moulton of my staff et (202) 219-7380.

Sincerely,
Stephen Mallinger,
Acting Director
Office of Health Compliance Assistance

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October 20, 1999
Richard Chinn, MS, CET
President Richard Chinn
Environmental Training, Inc.
P.O. Box 10776
Pompano Beach, FL 33061-6776

Dear Mr. Chinn:

This is a response to your March 24, 1999 letter about web-based training to satisfy the requirements of the Hazardous Waste Operations and Emergency Response (HAZWOPER) standard, 29 CFR 1910.120. You requested that OSHA confirm whether the web-based HAZWOPER refresher training your company provides meets the intent of the HAZWOPER standard with regard to hands-on training and trainer accessibility. Your description of the training and our response are below. We would like to apologize for the delay in responding to your letter.

Our company offers web-based training to satisfy the requirements of the Hazardous Waste Operations and Emergency Response Annual Refresher Training (29 CFR 1910.120(e)(8)). We offer a program from our web page whereby participants work through a series of pages and have to answer questions at the end of each section. If the participant receives less than a 70% score, he/she must repeat that section. We also require the following hands-on skills be demonstrated by the participant video-taping proper demonstration of:

  1. Cleaning a respirator
  2. Donning a respirator (including initial fit-testing)
  3. Doffing a respirator
  4. Donning the highest level suit the person would reasonably expect to wear<
  5. Air sampling with the equipment the participant would reasonably be expected to operate.

In addition, participants call our toll-free hotline or email us for answers. A Certified Environmental Trainer is available at designated times. It is our interpretation that our program satisfies OSHA's requirements for hands-on training and for having a trainer availability [sic]."

Response: We appreciate your interest in attempting to meet the intent of OSHA requirements. The issues of hands-on training and trainer availability are particularly important when employers choose to use a computer-based training (CBT) approach for health and safety training. Your emphasis on these two topics suggests that you are familiar with prior OSHA interpretations on this subject. For your reference, the two letters on our website that discuss CBT for HAZWOPER in some detail are the 11/22/94 letter to Jackie Ward and the 10/11/94 letter to Gerald Joy. Your specific request was that OSHA indicate whether your training program would satisfy HAZWOPER refresher training requirements. As a matter of policy, OSHA does not approve or endorse training programs. The employer, rather than the training provider, is ultimately responsible for ensuring that employees acquire the training and skills needed to perform their duties in a safe and healthful manner. We will, however, attempt to clarify our position on handson training and trainer availability for HAZWOPER training in relation to the program you describe. For HAZWOPER refresher training, OSHA indicated in the 11/22/94 letter to Ward that the employer may determine that hands-on training is unnecessary for a given refresher course. To make this determination, however, we indicated that the employer must assess the employees' skill level and ensure that the employees remain competent in their assigned duties. In general, OSHA encourages the use of hands-on training even in refresher courses because it is an effective means for auditing worker performance of safety-related skills. Hands-on training typically involves trainees interacting with equipment and tools in the presence of qualified trainers. This situation ensures that workers have an opportunity to learn or refresh their skills by experience and allows the trainer to assess whether workers have mastered the proper techniques. OSHA has no basis for evaluating your proposed approach to hands-on training, which involves trainees videotaping their demonstration of skills for trainer review. Unfortunately, studies that examine the effectiveness of technology-based training approaches among various worker populations do not seem to keep pace with the use of these approaches.

Our impression, however, is that this approach does not support the purpose of hands-on training. We question whether the limited and delayed interaction between the trainer and trainee allows the trainee to learn by experience. In addition, we can foresee limitations in a trainer's ability to evaluate a trainee's skills via videotape unless the video camera(s) can capture the performance from multiple angles and with good clarity. As a practical matter, this approach sounds as though it could be more time-consuming than traditional hands-on training if the trainee did not perform the skills correctly or if the videotape was not sufficiently clear. Your letter did not address how re-evaluation would be handled. Finally, with regard to the specific hands-on training topics you list, the choices appear to be limited. Donning and doffing personal protective equipment (PPE) other than a respirator, for example, is an important safety skill that many employers may want their employees to review.

As we stated above, however, the employer is ultimately responsible for ensuring that employees acquire the training and skills they need to perform their work safely and would need to evaluate your program with the employees' needs in mind. The employer is also ultimately responsible for providing access to a qualified trainer. Trainees must have an opportunity to ask and receive answers to questions where material is unfamiliar to them. Frequently, a trainee may be unable to go further with the training or to understand related training content until a response is received. OSHA has previously stated that, when web-based or computer-based training is used, a telephone hotline or e-mail satisfies OSHA's requirement for trainer access if the employee can ask and receive a responses from a qualified trainer in a timely manner. If an employer uses an outside computer-based or web-based training program that provides trainer access during limited periods, the employer could address the limitations on trainer access in several ways. One possibility would be to limit employee training to the hours when a qualified trainer is available. A second possibility would be to provide an in-house qualified trainer to answer questions during hours not covered by the outside training provider. A third possibility would be to ensure that the training program is designed so that trainees cannot progress further in the program if they cannot indicate mastery of topics upon which additional training is based. This last option cannot replace but can supplement access to a qualified trainer. I hope that you find this information helpful. Our enforcement guidance is subject to periodic review and clarification, amplification, or correction.

In the future, you can verify that the guidance provided above is still current by consulting OSHA's website at http://www.osha.gov. Finally, if you need further assistance on this matter, please contact the Office of Health Compliance Assistance at (202) 693-2190.

Sincerely,
Charles N. Jeffress
Assistant Secretary

 

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