Note: This information was adapted from HAZWOPER refresher training: hands-on training and trainer accessibility. Standard Number: 1910.120(e)(8), 1926.65(e)(8) Subject: Web-based HAZWOPER refresher training: hands-on training and trainer accessibility.
The issues of hands-on training and trainer availability are particularly important when employers choose to use a computer-based training (CBT) approach for health and safety training. As a matter of policy, OSHA does not approve or endorse training programs. The employer, rather than the training provider, is ultimately responsible for ensuring that employees acquire the training and skills needed to perform their duties in a safe and healthful manner.
The employer must assess the employees' skill level and ensure that the employees remain competent in their assigned duties. In general, OSHA encourages the use of hands-on training even in refresher courses because it is an effective means for auditing worker performance of safety-related skills.
Hands-on training typically involves trainees interacting with equipment and tools in the presence of qualified trainers. This situation ensures that workers have an opportunity to learn or refresh their skills by experience and allows the trainer to assess whether workers have mastered the proper techniques.
Due to the lack of trainer-trainee interaction inherent in most CBT training formats OSHA does not believe they typically meet the requirements or purposes of hands-on training.
The employer is also ultimately responsible for providing access to a qualified trainer. Trainees must have an opportunity to ask and receive answers to questions where material is unfamiliar to them. Frequently, a trainee may be unable to go further with the training or to understand related training content until a response is received.
OSHA has previously stated that, when web-based or computer-based training is used, a telephone hotline or e-mail satisfies OSHA's requirement for trainer access if the employee can ask and receive a responses from a qualified trainer in a timely manner.
If an employer uses an outside computer-based or web-based training program that provides trainer access during limited periods, the employer could address the limitations on trainer access in several ways. One possibility would be to limit employee training to the hours when a qualified trainer is available. A second possibility would be to provide an in-house qualified trainer to answer questions during hours not covered by the outside training provider. A third possibility would be to ensure that the training program is designed so that trainees cannot progress further in the program if they cannot indicate mastery of topics upon which additional training is based. This last option cannot replace but can supplement access to a qualified trainer.
Note: The following information was adapted from a letter from Ruth E. McCully, Director Office of Health Compliance Assistance to ENERGY Gulf States Utilities 11/22/94
In OSHA's view, self-paced, 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, in particular those of HAZWOPER.