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.

July 24, 2014

Mr. Stephen A. Newell, JD
ORCHSE Strategies, LLC
2100 M Street, NW
Suite 170-357
Washington, DC 20037

Dear Mr. Newell:

Thank you for your February 19, 2013, letter to the Occupational Safety and Health Administration (OSHA), regarding electrical training. Your letter was referred to OSHA's Directorate of Enforcement Programs (DEP) for response. We apologize for the delay in our response. We have paraphrased your questions, and our replies follow. This letter constitutes OSHA's interpretation only of the requirements discussed, and may not be applicable to any questions not delineated within your original correspondence.

Scenario: A company uses synchronous web-based training for electrical work. The training allows both the instructor and the student to interact in a virtual meeting with teleconferencing. Student engagement and comprehension is assessed through intermittent polling and quiz questions. Students are required to achieve a score of 80% correct on an end of course exam. Students failing the exam are retested once. If the student fails the retest, their manager determines whether reassignment to a task that does not utilize the training or additional retraining is more appropriate. Following successful training completion, students demonstrate their skills locally, using methods commensurate with the risk of the work they will perform.

Question: Does this training method comply with OSHA's standard at §1910.332(c)?

Response: 29 CFR 1910.332(c) states:

  • (c) Type of training. The training required by this section shall be of the classroom or on-the-job type. The degree of training provided shall be determined by the risk to the employee.

If employees demonstrate the knowledge and skills required for the work as a result of the training session, then the training method as described, including the local demonstration of skills, meets the requirements of 1910.332(c).

Thank you for your interest in occupational safety and health. If you have any further questions, please feel free to contact the Office of General Industry Enforcement at (202) 693-1850.

Sincerely,

Thomas Galassi, Director
Directorate of Enforcement Programs