Is Remote Safety Training Acceptable to OSHA?
During these times of dealing with the coronavirus (COVID-19) situation when many employers are asking their employees to work remotely, safety training must continue, but is training employees remotely compliant with OSHA? This question may be extended to the many online training providers that have been around for years that offer training on various topics.
I found e-training addressed on the Cal/OSHA website, which states, that “Cal/OSHA Consultation Service recognizes the value of providing information through the internet and other formats. Included are eTools with action kits….” So, Cal/OSHA recognizes that utilizing eTools for training can be an integral component of training. However, the Cal/OSHA website also states that the employee must demonstrate their understanding of the topic and obtain feedback from their employer. Cal/OSHA also suggests for this type of training to be effective that the employee demonstrate safe work practices or the proper use of tools and equipment. Simply having an employee watch a video is insufficient to meet Cal/OSHA’s training requirements.
The issue of remote training was specifically addressed by federal OSHA. In a July 11, 2019 Letter of Interpretation, the question was asked, “are online training programs acceptable for compliance with OSHA’s worker training requirement?” OSHA’s response was “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 unless that training contains interactive and hands-on components.” As is clear, online training is a valuable tool but, by itself, is insufficient for safety training.
Another key point raised in the Letter of Interpretation was the opportunity for workers to be able to ask questions and receive responses from “qualified trainer(s)”. Training with some level of interaction to ensure the employee’s understanding of the topic is critical. Also important is the opportunity for hands-on training so that the employee can demonstrate safe work practices. To this end, OSHA states, “online training that does not provide workers with hands-on training would not comply with OSHA’s worker training requirements.”
We encourage employers to continue to offer safety training to their employees working remotely. Maybe this is a good time for employers to discuss elements of ergonomics with their office personnel to ensure that the employee’s home work station is properly adjusted. If using online training providers, be sure that the provider uses qualified trainers who can answer employees’ questions. Let’s all ensure that employees receive the level of safety training needed so that they can continue to protect themselves and their co-workers when they return to work. The Cohen Group can assist with your online training needs.