Since the 1990s, videos and computers have become increasingly popular tools for safety and health training. Along the way, OSHA has raised concerns more than once about what it sees as the limits of online training for complying with agency standards. While OSHA repeated those concerns again earlier this year, it also appears ready for a new approach. What does OSHA say now about online training, and where may it be headed?
For years, OSHA has expressed concerns about relying too much on computer-based or online training. People have been asking OSHA formal questions about it since at least 1994. Consistently, OSHA has agreed that videos or “self-paced computer-based training” can be a valuable part of training. But, it also has raised concerns that such training can lack the kind of real-time opportunity for questions and answers, interactivity, and hands-on experiences that help trainees learn best.
This past July, an OSHA letter of interpretation extended these concerns even a bit further. In the past, OSHA was responding to questions about specific training requirements for a particular standard. But, this time, the question – and OSHA’s answer – seems more general. Past guidance had suggested that online training might be sufficient to fulfill some training requirements in OSHA regulations. This time, though, OSHA seemed to say even more broadly that online training “would not be sufficient” by itself unless it “contains interactive and hands-on components.”
What’s missing from computer-based training?
Based on the most recent guidance, OSHA has two major categories of concerns with online training:
First, training should allow for timely questions and answers, as well as interactivity.
- OSHA expects training to include “[t]he opportunity for workers to be able to ask questions of, and receive responses from, a qualified trainer(s), in a timely manner.”
- To ensure that employees can effectively learn the material, interaction should not be “delayed or limited.”
- For one solution, OSHA has suggested giving a telephone hotline number to workers who take online or computer-based courses so they can call a qualified trainer directly during the training.
Second, training should include hands-on experience.
- OSHA wants your training to include hands-on components.
- Employees should be able to “interact with equipment and tools in the presence of a qualified trainer(s).”
- Workers should be able to “learn or refresh their skills through experience.”
- Hands-on components also let trainers evaluate that the training was successful. Trainers should be able to “assess whether the trainees have mastered the proper techniques.”
OSHA has made similar points when setting the requirements for OSHA 10-hour and OSHA 30-hour training programs. Those courses must “be participatory” and include “interactive activities,” such as “workshops, case studies, exercises, and demonstrations that involve student participation and interaction.” In those programs, OSHA generally limits the amount of material delivered via videos, requires a minimum class size for more interaction, and tightly controls online delivery of courses. It expects two-way communication with trainers and quick responses to student questions.
A 20-year message: Online training can’t satisfy all OSHA requirements
In responding to questions about whether online training can comply, the agency has often emphasized that its various standards require different kinds of training for various situations and work activities. There is no one-size-fits-all rule. In last July’s letter, OSHA again “emphasize[d] the importance of reviewing specific OSHA standards and related guidance to determine what OSHA requires in specific situations.”
In past guidance, OSHA has said that computer-based training is insufficient to comply with a number particular training rules. Considering HAZWOPER training, in 1994, OSHA emphasized that its position on computer-based training was “essentially the same” as its view on training videos. OSHA worried that:
- Generic programs lack site-specific and job-specific training.
- Employees must be able to ask questions.
- Workers need opportunities to become “familiar with equipment and safe practices in a non-hazardous setting,” such as through hands-on training and exercises.
- Trainers need to be able to confirm that students “have mastered the necessary skills.”
Since then, OSHA has repeated these concerns and mentioned that online training alone is insufficient for a number of standards, including:
- Bloodborne pathogens (1997) (which requires site-specific elements, training for particular duties, and practice with PPE like removing gloves).
- HAZWOPER (2004) (where online training can be part of the program, but only if “supplemented by the opportunity for trainees to ask questions of a qualified trainer” and if providing trainees with “hands-on familiarity with protective equipment”).
- Powered industrial trucks (2011) (which requires practical demonstrations, exercises, and trainee evaluation).
- First and CPR (2012) (since “[t]hese standards require training in physical skills, such as bandaging and CPR. The only way these physical skills can be learned is by actually practicing them,” including practicing with mannequins and partners).
As OSHA now revisits online training, will virtual reality be a game-changer?
Against this backdrop, it’s interesting that OSHA just finished collecting comments on a possible “new online delivery model for OSHA’s Outreach Training Program” (10-hour and 30-hour courses). OSHA makes clear that these popular courses are voluntary and do not necessarily satisfy OSHA training requirements. They often need supplementation with site-specific, interactive, and/or hands-on components. Yet, these classes provide a significant foundation for many employees.
Since 2001, OSHA has authorized some training providers to provide 10-hour and 30-hour training programs online. However, in 2009, OSHA froze the online program and refused to accept new providers because it had received many complaints about fraud (people impersonating others), attempts to complete the training in less than the minimum required time, problems with timely issuance of completion cards, poor customer service and technical support, and misleading advertising. The new RFI explores new models to resolve these issues.
Interestingly, one issue that OSHA sought comment on is how interactive the online training should be. It has proposed four possible levels of interactivity – from purely passive (viewing text and graphics on screen and clicking to the next screen) to “limited” (adding some multiple choice questions), “complex” (adding filling in empty fields with answers), and “real time” (life-like simulation with cues and responses similar to virtual reality or flight simulators).
These suggestions raise a good question: Can’t new technology resolve OSHA’s long-running concerns about interactivity and hands-on experience with online training? For example, several companies appear to be selling virtual reality safety training that would allow a trainee to virtually step into an immersive work site and practice safety techniques. In the video below by 3M, a worker can practice putting on fall protection and working at heights safely on a virtual construction site (see other videos on this page). In the simulator, it all feels very “hands-on” and interactive – just what OSHA says it wants. It can also open up practical training to more workers and ironically, provide more “realistic” environments for practicing skills that most resemble the hazardous areas.
Maybe with the right technology, online training will soon be ready to meet virtually all OSHA training standards.
For now, though, where do your programs stand?
Until industry and OSHA adopt a VR training revolution, we’re still stuck in the present. So, does your training comply?
It’s worth reviewing your safety and health training programs to make sure that your company is not relying too much on online or computer-based training (whether that’s in-house or outsourced) if there are employees whose workplaces or activities would require more. That’s of particular concern where you have operations and employees who need training under standards that require real-time and/or hands-on interaction.
With any questions, or to discuss a cost-effective audit, please contact Avi Meyerstein or your Husch Blackwell attorney.