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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 https://www.osha.gov.
DOL-OSHA-DEP-2020-007 - This document does not have the force and effect of law and is not meant to bind the public in any way. This document is intended only to provide clarity to the public regarding existing requirements under the law or agency policies.
August 10, 2020
Mr. Michael Owen
QES Associates, LLC
3250 Roscommon Drive
Glenelg, MD 21737
Dear Mr. Owen:
Thank you for your letter to the Occupational Safety and Health Administration (OSHA) regarding the adequacy of meeting OSHA’s training requirements when a training is provided using online tools. Additionally, in an electronic correspondence to OSHA, you requested OSHA to address the growing field of virtual reality safety and health training. This letter constitutes OSHA’s interpretation only of the requirements herein, and may not be applicable to any questions not delineated in your original correspondence. Your paraphrased questions and our responses follow.
Question: We have been told online, commercially available, training tools meet OSHA’s training requirements. Can an employer meet OSHA’s training requirements when the training is provided online only? Additionally, would the use of virtual reality as the sole medium for providing safety and health training be acceptable to OSHA?
Response: Many OSHA standards require that employees receive training so that they can perform work in a safe and healthful manner. OSHA’s publication, OSHA 2254, found at www.osha.gov/Publications/osha2254.pdf, provides a list of OSHA training requirements. This publication contains a variety of specific requirements related to employee training as of 2015. Some of the standards listed in OSHA 2254 require “adequate” or “effective” training or instruction. Whether online or virtual reality training methods provide “adequate” or “effective” training may only be determined on a case-by-case basis. Employers need to examine the standards applicable to their workplaces and determine whether the training tools (such as online or virtual reality) they are using advance their employees’ overall comprehension and understanding of workplace hazards.
Effective safety and health training should include hands-on instruction and exercises, which provide employees the opportunity to become familiar with protective measures such as personal protective equipment, and safe workplace practices. For example, the purpose of hands-on training in the donning and doffing of personal protective equipment is two-fold: first, to ensure that workers have an opportunity to learn by experience and second, to assess whether workers have learned to use the protective gear competently.
In some instances, effective training must also provide an opportunity for interactive questions and answers. For example, 29 CFR § 1910.1030(g)(2)(vii)(N) (the Bloodborne Pathogens standard) requires “[a]n opportunity for interactive questions and answers with the person conducting the training session.” When training is provided online or in a virtual reality environment, this requirement may not be met if such an opportunity is not made available.
Additionally, some OSHA standards, such as the Hazardous Waste Operations and Emergency Response (HAZWOPER) standard, 29 CFR §1910.120, and electric power generation, transmission, and distribution, 29 CFR §1910.269, require site and/or job specific training. Sole reliance on online or virtual reality-based training programs may not provide such site and/or job specific training. Therefore, the adequacy and effectiveness of safety and health training provided by an employer to his or her employees may only be determined based on the facts of each particular case.
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 www.osha.gov. If you have any questions, please feel free to contact the Directorate of Enforcement Programs at (202) 693-2100.
Patrick J. Kapust, Acting Director
Directorate of Enforcement Programs