October 11, 1994
Mr. Gerald J. Joy
Health and Safety Director
ICF Kaiser Engineers, Inc.
Environment and Energy Group
Four Gateway Center
Pittsburgh, Pennsylvania 15222-1207
Dear Mr. Joy:
Thank you for your letter of December 29,
1993, forwarded to OSHA's
Directorate of Compliance Programs from our
Directorate of Technical Support, concerning
the Occupational Safety and Health Administration's
(OSHA) Hazardous Waste Operations and Emergency
Response (HAZWOPER) regulation, 29 CFR 1910.120.
Please accept my apology for the delay in
Your question requests clarification
on the acceptability of a computer based,
self-paced training program for use in meeting
the refresher training requirements of the
standard. Based on the information you have
provided, it is not possible for OSHA to
assess the effectiveness of the particular
computer-based training program in question.
We will address in more general terms the
issue of computer-based training before answering
your specific question on the refresher training
required in paragraph (e)(8) of the standard.
In OSHA's view, self paced, interactive
computer-based training can serve as a valuable
training tool in the context of an over-all
HAZWOPER training program. However, use
of computer-based training by itself would
not be sufficient to meet the intent of the
standard's various training requirements.
Our position on this matter is essentially
the same as our policy on the use of training
videos, as the two approaches have similar
shortcomings. OSHA urges employers to be
wary of relaying solely on generic "packaged"
training programs in meeting their training
requirements. Training required under HAZWOPER
includes site-specific elements and should
also to some degree be tailored to workers'
In order for the training to be effective,
trainees must have the opportunity to ask
questions. This requirement could be met
by providing a telephone hotline so that
trainees will have direct access to a qualified
trainer. The trainees' mastery of covered
knowledge and skills must also be assessed.
It is not clear whether "validation of course-work
completion" as described in the advertisement
you enclosed means that this particular computer-based
training program actually assesses whether
workers have mastered the covered material.
Hazardous waste operations can involve
many complex and hazardous tasks. It is imperative
that employees be able to perform such tasks
safely. Thus, auditing of worker performance
is required for all types of HAZWOPER training.
In the case of refresher training, this requirement
for auditing of worker performance could
be addressed during periodic safety meetings.
Traditional, hands-on training is the
preferred method. The purpose of hands-on
training, for example in the donning and
doffing of personal protective equipment,
is two-fold: first, to ensure that workers
have an opportunity to learn by experience,
and second, to assess whether workers have
mastered the necessary skills. The employer
may determine that hands-on training is unnecessary
for a given refresher course. However, if
an employer elects not to use hands-on training
in their refresher course, the employer must
first assess the employees' skill level,
and ensure that workers remain competent
in their current and any newly assigned duties.
In conclusion, it is possible in some
cases to use computer-based training in meeting
the refresher training requirements of 29
CFR 1910.120(e)(8), provided that the computer-based
training covers topics relevant to workers'
assigned duties and is supplemented by the
opportunity to ask questions of a qualified
trainer, as well as an assessment of worker
skill degredation through auditing of hands-on
performance of work tasks.
We hope this information is helpful.
If you have further questions please feel
free to contact the Office of Health Compliance
Assistance (202) 693-2190.
Ruth E. McCully
Director Office of Health Compliance