Is online or computer-based training acceptable for HAZWOPER refresher training?

In OSHA’s view, HAZWOPER online training, by itself, is not sufficient to meet the intent of the agency’s training requirements for HAZWOPER, 1910.120 for general industry or 1926.65 for construction. Therefore, with one exception described below, online training must be supplemented by site-specific elements, hands-on training and exercises, and an opportunity for trainees to ask questions of a qualified trainer. When using online training as a tool to help with refresher training under 1910.120/1926.65, it is important to do all of the following:

• Ensure your trainer is qualified, in accordance with 1910.120/1926.65.
• Augment the online training with site-specific elements.
• Tailor your training to the employees’ assigned duties.
• Include hands-on training to re-familiarize trainees with equipment, personal protective equipment, and safe practices.
• Provide trainees with immediate and direct access to a qualified trainer as they are taking the course.
• Offer an opportunity for trainees to ask questions of the qualified trainer.
• Ensure all training elements listed in the regulation are covered.
• Meet the training duration requirement. However, under 1910.120(q)(8)/ 1926.65(q)(8), ensure that the trainees receive refresher training in “sufficient content and duration” to maintain competencies listed for the trainees particular level under paragraph (q)(6). NOTE: The online training course curriculum may not be intended to fill the required training duration, and it may be anticipated that the remaining required duration will be filled with the items in the suggested bullet items above.
• Ensure the certification requirements are met by making sure the required persons, e.g., employer and/or trainer, properly certify the refresher training. NOTE: The online training course curriculum may not necessarily provide proper HAZWOPER certification or HAZWOPER statements of training. The online course curriculum certificate might only acknowledge the completion of the online training itself.

For HAZWOPER refresher training under 1910.120(e)(8) and 1926.65(e)(8), OSHA indicates in a 10/11/1994 letter that the employer may determine that hands-on training is unnecessary for a given refresher course. To make this determination, however, OSHA indicates that the employer must assess the employees’ skill level and ensure that the employees remain competent in their assigned duties. In general, OSHA encourages the use of hands-on training even in refresher courses because it is an effective means for auditing worker performance of safety-related skills.