OSHA Directives

CPL 02-02-071 - Technical Enforcement and Assistance Guidelines for Hazardous waste Site and RCRA Corrective Action Clean-Up Operations HAZWOPER 1910.120 (b)-(o)

Note:  The following information describes OSHA's current veiw on computer-based training programs including hands-on training and the ability of employees to ask questions.  Because this is a rapidly developing area, you should periodically check the OSHA website for new interpretive letters on this topic.

In OSHA's view, 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.  However, self-paced, interactive computer-based training can serve as a valuable training tool in the context of an overall training program.  Our position on this matter is essentially the same as our policy on the use of training videos, since the two approaches have similar shortcomings.  OSHA urges employers to be wary of relying solely on generic, packaged training programs in meeting their training requirements.  For example, training under HAZWOPER includes site-specific elements and should also, to some degree, be tailored to workers' assigned duties.

In an effective training program, it is critical that trainees have the opportunity to ask questions where material is unfamiliar to them.  In a computer-based program, this requirement may be met by providing a telelphone hotline so that trainees will have direct access to a qualified trainer.  Equally important is the use of hands-on training and exercises to provide trainees with an opportunity to become familiar with equipment and safe practices in a non-hazardous setting.  Many industrial operations, and in particular hazardous waste operations, can involve complex and hazardous tasks.  It is imperative that employees be able to perform such tasks safely.  Traditional, hands-on training is the preferred method to ensure that workers are prepared to safely perform these tasks.  The purpose of hands-on training, for example in putting on and removing 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 mastered the necessary skills.  It is unlikely that sole reliance on a computer-based training program is likely to achieve these objectives.

Thus, OSHA believes that computer-based trianing programs can be used as part of an effective safety and health training program to satisfy OSHA training requirements, provided that the program is supplemented by the opportunity for trainees to ask questions of a qualified trainer, and provides trainees with sufficient hands-on experience.

For further information on this OSHA directive, visit the OSHA website