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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.
July 11, 2019
Mr. Anthony Chibbaro
1300 Morris Park Avenue
Room 800 Forcheimer
Bronx, New York 10461
Dear Mr. Chibbaro:
Thank you for your letter to the Occupational Safety and Health Administration (OSHA). Your letter was forwarded to the Directorate of Enforcement Programs (DEP) for a response. You specifically had questions related to whether workers completing on-line training programs are acceptable. Your questions have been paraphrased below, followed by OSHA's responses. This letter constitutes OSHA's interpretation only of the requirements herein, and may not be applicable to any questions not delineated within your original correspondence.
Question 1: Are online training programs acceptable for compliance with OSHA's worker training requirements?
Response: 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). OSHA emphasizes the importance of reviewing specific OSHA standards and related guidance to determine what OSHA requires in specific situations.
Question 2: Is a worker's signature necessary for compliance with safety requirements for worker training taken online?
Response: Obtaining an employee's signature following training is generally not required by OSHA's standards. Although a search of OSHA's standards by this office did not reveal any standard that requires the employer to obtain the employee's signature, employers should consult applicable OSHA standards to ensure compliance with those standards.
Thank you for your interest in occupational safety and health. We hope you find this information helpful. OSHA's requirements are set by statute, standards, and regulations. Our letters of interpretation do not create new or additional requirements but rather explain these requirements and how they apply to particular circumstances. This letter constitutes OSHA's interpretation of the requirements discussed. From time to time, letters are affected when the Agency updates a standard, a legal decision impacts a standard, or changes in technology affect the interpretation. To assure that you are using the correct information and guidance, please consult OSHA's website at http://www.osha.gov. If you have further questions, please feel free to contact the Directorate of Enforcement Programs at (202) 693-2100.
Patrick J. Kapust, Acting Director
Directorate of Enforcement Programs