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 this response.

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' assigned duties.

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.

Sincerely,

Ruth E. McCully, Director Office of Health Compliance Assistance