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You are here: Experts > Industry > Industrial Health and Safety > Occupational (OSHA) and Environmental Hazards > Requirements of 29CFR 1910.331-335
Expert: Mike Brown CSP Retired - 11/5/2009
Question
If I give my employees online training in a classroom setting will this meet the requirements of 29CFR section 1910.331-335 and if so, how should it be documented?
Answer
Subject: Requirements of 29CFR 1910.331-335
Question: If I give my employees online training in a classroom setting will this meet the requirements of 29CFR section 1910.331-335 and if so, how should it be documented?
Answer: James, on-line training can be a part of the training required for this section of the regulations if several other components are included. Training starts with the presentation that is made to the employees. Does it cover all portions of the codes which apply to a specific individual and is it sufficiently detailed? This can be documented by a detailed instructor’s outline of the material presented, the method of presentation and a listing of aids used in the training and copies of any or all handout material given the employee. You will also need to document the date, time and place the training was given to show it was done on a regular basis and updated as required. A written quiz or test can be used to show that an individual understood the material and requirements. Recently, there has been more and more emphasis placed on performance based testing. This would involve taking a person out into the plant and watching them perform a procedure such as locking out a piece of equipment prior to maintenance and documenting the test with a checklist which would include the date, time, and signatures of the person administering the test as well as that of the employee being tested. This helps prove the training was not only given but also understood. This would also be needed for other tasks such as using and maintaining a respirator or similar task.
You should check with others in your industry and/or area to determine what they are doing and what the results have been. There are a number of firms that market employee training packages and they may have ideas you can “borrow”.
Summary: You must be able to show through proper and acceptable documentation that an employee was trained on the topic – when and where, what the training included, and that by examination – written and performance, the employee fully understood the training. How this all is done is up to the employer. If you can accomplish some of the training using on-line processes then that should be acceptable as long as that training meets the overall requirements. And you have the proper “paper-trail”. I hope this provides the necessary information, if I can be of further assistance please feel free to ask additional questions.
Michael Brown, CSP Retired
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