The following is the interpretation from OSHA. There are interpretation letters back to 1994 and now this one from 2019 in regards to similar questions. Are online training programs acceptable compliance with OSHA’s training requirements.
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.
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.
Sincerely,
Patrick J. Kapust, Acting Director
Directorate of Enforcement Programs
Enclosure
