OSHA’s July, 2019 Letter of Interpretation on Online Safety Training

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January 7, 2020

Resource: Blog Industry: Industrial
Tags: Safety, Vector EHS Management

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This past year, OSHA issued a letter of interpretation (LI) about using online safety training (read the OSHA LOI here).

The 2019 letter of interpretation didn't change OSHA's basic take on using online safety training at work: as OSHA had already made clear in a 1994 letter of interpretation, it IS fine to use online safety training. We discussed that in our earlier blog post, What Does OSHA Say about Online Safety and Health Training?

But this more recent LI from OSHA does give some additional guidance on how to use online safety training. We'll explain for you what OSHA had to say about that below.

You might also find a LOT of stuff interesting and helpful on your online safety training search in the guide below.

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As we mentioned earlier, OSHA's made it clear since the 1990s that it's OK to use online safety training at work:

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.

But the letter of interpretation OSHA published in 2019 gave guidance on HOW to use online safety training (and how not to). Here is the key material from the more recent OSHA LI on online safety training:

Online, self-paced computer-based training can be a valuable part of an effective safety and health training program. However, the use of online training by itself would not be sufficient to satisfy OSHA training requirements unless that training contains interactive and hands-on components. To be effective, training must result in mastery of the training material (such as, for example, safe work practices or the safe and appropriate use of tools and personal protective equipment). Online training without interactive and hands-on components would not meet this goal.

The opportunity for workers to be able to ask questions of, and receive responses from, a qualified trainer(s), in a timely manner, is critical to effective training. Online training that does not provide workers with this opportunity would not comply with OSHA's worker training requirements. Training with no interaction, or delayed or limited interaction, between the trainer and trainee may halt or negatively affect a trainee's ability to understand and/or retain the training material. OSHA notes that one way for the employer to give workers this opportunity in the context of a computer-based program is to provide a telephone hotline so that workers will have direct access to a qualified trainer during the conduct of the online training.

Equally important is the provision of sufficient hands-on training because it allows an employee to interact with equipment and tools in the presence of a qualified trainer(s), allows the employee to learn or refresh their skills through experience, and allows the trainer to assess whether the trainees have mastered the proper techniques. Online training that does not provide workers with hands-on training would not comply with OSHA's worker training requirements. See letter of interpretation to Ms. Jackie Ward (Nov. 22, 1994) (copy enclosed).

So what are the key takeaways there?

The first is that you CAN use online safety training but you CAN'T use only online safety training. You've got to add (1) interactive and (2) hands-on elements. Learning professionals call this blending of online training with face-to-face, interpersonal training a blended learning solution. To learn more about blended learning, check out our article on Best Practices for Blended Learning and download our free Blended Learning Beginner's Guide.

The second is that OSHA requires interaction as part of safety training. By interaction, they mean the worker must be able to "ask questions of, and receive responses from, a qualified trainer(s), in a timely manner." OSHA gives some examples of how that interaction can occur--they're even OK with giving the employee the ability to call a qualified trainer using a telephone hotline.

And the third takeaway is that OSHA requires training that includes hands-on training. As they put it, "Online training that does not provide workers with hands-on training would not comply with OSHA's worker training requirements."

Hope that helps clear things up! Let us know if you have any additional questions about online safety training (we make great online health and safety training courses and learning management systems), and don't forget to download the safety training guide, below.

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