- Standard Number:
OSHA requirements are set by statute, standards and regulations. Our interpretation letters explain these requirements and how they apply to particular circumstances, but they cannot create additional employer obligations. This letter constitutes OSHA's interpretation of the requirements discussed. Note that our enforcement guidance may be affected by changes to OSHA rules. Also, from time to time we update our guidance in response to new information. To keep apprised of such developments, you can consult OSHA's website at http://www.osha.gov.
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.
Stephen Mallinger, Acting Director
Office of Health Compliance Assistance
May 27, 1997
Mr. John Miles Director Compliance Programs
US Department of Labor
Occupational Safety and Health Administration
200 Constitution Ave., N.W.
Washington, DC 20210
Dear Mr. Miles;
I recently attended the American Industrial Hygiene Conference and was struck by the growing field of interactive CD-ROM training programs that are becoming available. I have several clients that could benefit from safety training programs developed around the CD-ROM. However, I am concerned about OSHA standards that require a hands on or interactive approach to training.
Of particular concern at the present time is the Blood Borne pathogens standard. I have reviewed the interpretation concerning the use of video presentations for blood borne issued September 8, 199. The interactive CD-ROM is a more interactive training tool than video alone.
My question to you is what is OSHA's view on the use of interactive CD-ROM? Can it be used as a stand alone training tool or must it be supplemented by actual human contact to be acceptable?
I look forward to receiving your answer soon.
Anna E. Jolly, JD, CHMM