Does the use of computer- and video-based training programs satisfy OSHA training requirements?
In 1997, OSHA issued a Standards Interpretation addressing this question. Such training can be valuable, “in the context of an overall training program.” But, the Interpretation continued:
“[U]se of computer-based training by itself would not be sufficient to meet the intent of most of OSHA’s training requirements. 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’ programs in meeting their training requirements.”
The Interpretation added that it’s “equally important” for employers to:
“Use hands-on training and exercises to provide trainees with an opportunity to become familiar with equipment, personal protective equipment, and safe practices (e.g., glove removal) in a non-hazardous setting. It is unlikely that sole reliance on a computer-based training program is likely to achieve these objectives.”
It’s not hard to understand why OSHA takes the position that relying exclusively on off-the-shelf products to train your workers doesn’t satisfy the employer’s legal duty to provide training. Such products have three major weaknesses:
They’re Too Generic: Many training products, especially web-based programs, tapes and DVDs, utilize a cookie cutter approach. Consequently, they often fail to address all of the hazards present in the particular workplace. Others, such as products on incident investigations, should be delivered in a classroom not on a computer.
They’re Technically Inadequate: In many cases, training products lack the technical background or depth necessary to withstand scrutiny in court. This fact alone increases a company’s liability risks. After all, if legal action is taken against an employer for failure to provide adequate training, the qualifications of the trainer and technical adequacy of the training material will serve as crucial evidence.
They Don’t Provide for Documentation: Off-the-shelf training programs may address the topic adequately but still fail to provide a method to confirm that trainees learned the material. Some products include forms documenting that training was delivered. But simply delivering training isn’t enough to ensure compliance. Employers must also verify that the training was effective. Without proof that the training material was absorbed, all an employee would need to say is that he didn’t understand the lesson to expose the company to liability.
Off-the-shelf training products can enhance safety training but should not serve as the sole basis of training. To ensure compliance with OSHA training requirements, each employer must determine exactly what kind of training its employees need, how best to deliver that training and how to evaluate and verify that the training is working.