Does the use of computer- and video-based training programs satisfy OSHA training requirements? Let's address that question now.

The 1997 OSHA Interpretation

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."

[Standard Interpretations, 6/11/97, Appropriateness of computer-based interactive training programs to satisfy required OSHA training.]

Other Problems with Canned Training

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.

Conclusion

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. Although I'm not allowed to promote my product on SafetyXChange, I can tell you that my company, Vanguard Environmental, Inc. is designed to provide the kind of training that meets all of these requirements and that it's based on the specific needs of the employer.

But whether you use Vanguard, another company's products or provide for all training internally, just bear in mind that to withstand scrutiny, your training program must be specific, technically adequate and verifiable.

THE CANADIAN PERSPECTIVE

By Glenn Demby

Training requirements under provincial OHS laws are similar to OSHA. So the principles and advice in Bob's story apply equally well to Canadians.

EMPLOYERS IN COURT

Company Fined for Not Verifying Training

By Glenn Demby

Here's an actual case from the Occupational Safety Health and Review Commission that demonstrates some of the points about training that Bob makes in his article.

The case involves a crane operator and a less experienced rigger who were moving a stack of concrete pilings, each weighing approximately 6,000 pounds. Because his view was obstructed, the crane operator simply placed the pilings where the inexperienced rigger told him they should go. After he drove away, all of the pilings fell. When he left his crane to investigate, he saw that the rigger had been crushed to death. After an inspection, OSHA fined the company for failing to implement adequate training and work rules to ensure that the workers knew how to perform their jobs safely.

The company had given each new worker a safety manual and on-the-job safety training. It also held weekly tool box safety meetings and thought it was doing enough to make sure workers understood how to perform their job safely. But it never tested them on what they knew. During the five months that the inexperienced rigger had been on the job, he received at least one written reprimand for putting too many pilings on a stack and creating the risk that they would fall. The company also wrote him up for safety lapses on at least two other occasions. But it never gave him additional training because nobody knew that he didn't know how to do his job properly -- they just thought he was slacking off. If someone had taken the time to verify whether the rigger understood the correct way to stack concrete pilings, the accident could have been avoided.

Secretary of Labor v. Gary Concrete Products, Inc., OSHRC Docket No. 86-1087 (May 16, 1991).

CORRECTION

Josiah Bartlett: One of three men from New Hampshire to sign the Declaration of Independence

New Hampshire & the Declaration of Independence

By Glenn Demby

Last Thursday's issue of the SafetyXChange newsletter furnished a brief sketch of all 56 men who signed the Declaration of Independence on July 4, 1776. At least it was supposed to. Because of a technical glitch, we inadvertently omitted the members of the New Hampshire delegation who put their signatures to the Declaration. SafetyXChange apologizes for the error - especially to those of you who come from the great State of New Hampshire. Here are the New Hampshire signers:

NEW HAMPSHIRE

Josiah Bartlett: A frontier physician and the second man to sign the Declaration after John Hancock. Became Chief Justice of the New Hampshire Supreme Court even though he wasn't a lawyer.

Matthew Thornton: His family emigrated to the U.S. from Ireland when Matthew was 3. A physician who served as first President of the New Hampshire House of Representatives. Later became a political essayist who ran a farm and a ferry company in Merrimack, NH.

William Whipple: A merchant who would go on to command a brigade of New Hampshire militia during the defeat of the British army of General Burgoyne in the Battle of Saratoga. Became a judge. Died by fainting while riding his horse on the way to court.

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