• HAZWOPER training can include a computer-based component, as long as the overall training program provides employees with hands-on experience and the ability to ask questions of a trainer.

According to the Occupational Safety and Health Administration (OSHA), use of computer-based (or online) training by itself is not sufficient to meet the intent of most of OSHA’s training requirements, in particular those of the Hazardous Waste Operations and Emergency Response (HAZWOPER) Standard. However, self-paced, interactive computer-based training can serve as a valuable training tool in the context of an overall training program. OSHA’s position on this matter is essentially the same as the agency’s 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” training programs in meeting the agency’s training requirements. For example, training under HAZWOPER requires site-specific elements and should also, to some degree, be tailored to employees’ assigned duties.

In an effective training program, it is critical that trainees have the opportunity to ask questions where material is unfamiliar to them. In a computer-based program, HAZWOPER training requirements may be met by providing a telephone hotline so that trainees will have direct access to a qualified trainer.

Equally important is the use of hands-on training and exercises to provide trainees with an opportunity to become familiar with equipment and safe practices in a non-hazardous setting. Many industrial operations, and in particular hazardous waste operations, can involve complex and hazardous tasks. It is imperative that employees be able to perform such tasks safely.

Traditional, hands-on training is the preferred method to ensure that workers are prepared to safely perform these tasks. The purpose of hands-on training, for example in putting on and removing personal protective equipment (PPE), is twofold:

1. To ensure that employees have an opportunity to learn by experience, and
2. To assess whether employees have mastered the necessary skills.

Sole reliance on a computer-based training program is unlikely to achieve these objectives.

Thus, OSHA believes that computer-based training programs can be used as part of an effective safety and health training program to satisfy OSHA training requirements, provided that the program is supplemented by the opportunity for trainees to ask questions of a qualified trainer and provides trainees with sufficient hands-on experience.