In a 2019 Letter of Interpretation, OSHA re-asserted its position on the effectiveness of online safety training. The letter was a response to an employer who asked, “Are online training programs acceptable for compliance with OSHA’s worker training requirements?” In its answer, OSHA says that “online, self-paced training can be a valuable part of an effective safety and health training program.”  The key word here is “part.” OSHA goes on to say that to be sufficient, online safety training must include interactive and hands-on components. In other words, OSHA recognizes the value that online safety training provides, but makes it clear that online training is only one piece of an effective safety program.  What Does This Mean for Employers?  Let’s use a simple example to explore the role of online safety training for employees.  OSHA’s Standard for portable fire extinguishers requires that, when fire extinguishers are provided for employee use, the employer must provide training (and annual re-training) for employees who will use them. This training must “familiarize employees with the general principles of fire extinguisher use and the hazards involved with incipient stage fire fighting” (29 CFR 1910.157(g)(1)).   An online fire extinguisher safety course could easily cover:  • different types of fire extinguishers • how to choose the right extinguisher for a specific fire  • the PASS technique  • answers to frequently asked questions  What a typical OSHA online course could not cover, however, are more hands-on and site-specific elements that should be included in training, including:  • the location of fire extinguishers in the employee’s workplace  • the opportunity to practice and gain proficiency in using a fire extinguisher  When online instruction is used to meet any OSHA worker training requirement, employers should keep in mind the inherent limitations of the format and be prepared to supplement online training with hands-on practice and site-specific information as needed. For fire extinguisher training, an online course could certainly be used to cover the basics, provided the employee’s manager also makes time for workers to practice using the tools and techniques for effective fire-fighting.  Q&A Is Integral to Learning  In the same interpretation letter, OSHA states that “the opportunity for workers to ask questions of, and receive responses from, a qualified trainer, in a timely manner, is critical to effective training.”   When it comes to safety training for employees, a manager or safety professional on staff may have answers to all possible questions about a given topic—or he or she may not.  When choosing online training, safety leaders should research providers before enrolling any workers. Does the provider employ subject matter experts who can answer an employees’ questions when needed? Does the online course include an option to submit questions and receive answers?  Asking questions is an indispensable part of learning. Employees who can ask questions and get answers during training will retain more of what they learn and be better prepared to apply their safety knowledge to real workplace scenarios. If an online course chosen does not provide an opportunity for Q&A, the employer must ensure the employees’ questions are answered by a qualified individual during the training.  Why Managers Choose Online Safety Training  Employers incorporate online courses into their training programs for many reasons. Online training can limit downtime, improve retention of information, and allow for a self-paced learning experience. Not least of all, an online course is often the most cost-effective option for training employees.   By understanding the level of training that an online course can provide, managers can ensure employees get all the information and experience needed to protect themselves and their co-workers on the job—and fully comply with OSHA training requirements.

ROGER MARKS is the head content writer for Lion Technology Inc., a leading provider of hazardous materials, environmental, and safety training. Lion offers courses in a variety of formats: instructor-led workshops, self-paced online courses, and live webinars.
Can Online Training Satisfy OSHA Requirements?
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