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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.
August 3, 1999
Mr. Chip Macdonald
P.O. Box 4427
Saratoga Springs, New York 12866
Re: Sole use of video tapes to meet OSHA training requirements
Dear Mr. Macdonald:
This is in response to your letter dated March 3, 1999. You ask whether an employer may rely entirely on training videos to comply with the Occupational Safety and Health Administration's (OSHA) training requirements in 29 CFR 1926.21. You point out that training solely through standardized videos is not interactive, hands-on, or site-specific, and that it does not include testing.
Section 1926.21(b)(2)-(6) requires employers engaged in construction to instruct their employees in the recognition and avoidance of unsafe conditions, the applicable regulations, and with respect to several specific hazards and practices necessary to deal with them safely. In addition, there are other, more specific construction standards that also have training requirements (for example, 1910.178, Powered Industrial Trucks, which is applicable to construction through 1926.602(d), (enacted December 1, 1998), and 29 CFR 1926 Subpart L, scaffolds).
The instruction that employers must provide under §1926.21 must be tailored to the employees' language and level of education, the hazards its employees will encounter, and convey the required information. In short, we consider this standard to require effective training. While it does not expressly require training that is interactive and hands-on, it is often more difficult to provide effective training that lacks these elements. In some cases it would be extremely difficult, if not impossible, to provide effective training in the absence of site-specific instruction, especially with respect to hazards such as confined spaces. Hands-on training may also be essential at times, especially when training on hazards associated with equipment. This provision does not expressly require formal testing, but we consider the standard to require employers to take reasonable steps to ascertain if the employees understand what they have been taught.
Where more specifically applicable training standards apply, such as for Powered Industrial Trucks, employers are required to meet those training requirements, most of which are more detailed than
If you have any additional questions, please write to: the Directorate of Construction, Office of Construction Standards and Compliance Assistance, 200 Constitution Avenue, N.W., N3476, Washington, D.C. 20210.
Russell B. Swanson, Director
Directorate of Construction