OSHA has a lot to say about online training; it’s just hard
to find it all and then see any clear policy. Most of their interpretation
letters on the topic are related to HAZWOPER training, but they have a policy
statement that says how training should be provided (below). OSHA’s own Outreach
Training Program “accepts” online training for 10- and 30-hour training
programs.
Here’s an excerpt from the OSHA training Standards Policy
Statement (4/17/07):
“It is the Agency's position that, regardless of the precise
regulatory language, the terms "train" and "instruct," as
well as other synonyms, mean to present information in a manner that employees
receiving it are capable of understanding. Training and instruction mean
imparting information, a definition that implies the information is presented
in a manner the recipient is capable of understanding.”
Here’s what OSHA tells its inspectors to do in the same
policy statement:
“If a reasonable person would conclude that the employer had
not conveyed the training to its employees in a manner they were capable of
understanding, then the violation may be cited as serious if it is within the
guidelines set out in the Field Inspection Reference Manual.”
“For
example, Lockout/Tagout (1910.147(c)(7)(i)) requires the employer to verify that
the employees have “acquired” the knowledge and skills which they have been
trained. The
Bloodborne Pathogens rule (1910.1030(g)(2)(vii)(N)) says training must
offer “
n opportunity for interactive questions and answers with the person
conducting the training session.”
This reinforces
the need for a live trainer somewhere in the training program.
OSHA’s Outreach Training Program website says it has a list
of sources that OSHA has accepted for on-line training for 10- or 30-hour general
industry and construction outreach courses. You have to send OSHA an email to
get the list of accepted sources.
One of
OSHA’s requirements for “accepting” a vendor’s online 10- or 30-hour training
program is “
asy trainer availability built into the system.” This
means the person taking an online course must have “easy” access to a trainer
by phone, fax, or other two-way communication. I’m not absolutely sure of this,
but some OSHA guidance on this stated that a trainer must respond to the online
trainee’s questions within 24 hours.
vc