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Hazardous waste training, online or hands-on?

A guest post by Russ Phifer, a consultant with WC Environmental and past chair of the ACS Division of Chemical Health & Safety.

Hazardous waste handlers, people involved in waste clean-up operations, and hazmat emergency responders must be trained in OSHA’s Hazardous Waste Operations and Emergency Response Standard (HAZWOPER). As someone who provides safety training, both online and on-site, I’ve been stuck somewhere between amused and alarmed at the number and scope of companies claiming to offer 40-hour, online-only OSHA HAZWOPER training.

The standard itself, in 29CFR 1910.120, doesn’t go into a lot of detail on the training that must be provided initially:

General site workers (such as equipment operators, general laborers and supervisory personnel) engaged in hazardous substance removal or other activities which expose or potentially expose workers to hazardous substances and health hazards shall receive a minimum of 40 hours of instruction off the site, and a minimum of three days actual field experience under the direct supervision of a trained experienced supervisor.

This would seem to imply that the 40 hours of instruction could be by any feasible means. However, looking further at how OSHA has interpreted the training requirements reveals clearly that there is a hands-on requirement and more. According to an OSHA interpretation:

In OSHA’s view, self-paced, interactive computer-based training can serve as a valuable training tool in the context of an overall training program. However, use of computer-based training by itself would not be sufficient to meet the intent of most of OSHA’s training requirements, in particular those of HAZWOPER. Our position on this matter is essentially the same as our 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 their training requirements. For example, training under HAZWOPER includes site-specific elements and should also, to some degree, be tailored to workers’ assigned duties. …

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. … It is unlikely that sole reliance on a computer-based training program is likely to achieve these objectives.

There are other interpretations from OSHA that also make clear the need for hands-on training, particularly in relation to donning and doffing personal protective equipment and working with site-specific equipment.

So how is it that one provider of online 40-hour training can offer this claim?

For those students who are looking to take the OSHA 40 Hour HAZWOPER training from their computer via the internet, we offer a course that can be completed entirely online. Instead of hands-on training, students are shown over 50 short video clips as if they were at the 8-hour hands-on session. These video clips are required viewing by each participant. The video clips demonstrate HAZWOPER equipment in great detail and students have the advantage to review the videos over and over as needed during their course.

And, from another provider:

We usually recommend online training to individuals who prefer a relaxed, comfortable, self-paced environment and on-site training for those who desire a more “hands-on” learning experience. In general, online learning is the more cost-effective choice for the individual learner.

It seems to me that the employer is risking a great deal by trying to document 40-hour training solely through online sources. Yet there are several providers who claim their courses are “OSHA Accepted” or “OSHA verified.” We’re not talking one or two sites–there appear to be dozens offering this training online! My favorite is a provider advertising: “Need a Certificate Now? A temporary printable certificate will be made available immediately upon successful completion of course.”

Some of these sites do have disclaimers regarding the need for hands-on training, though I’m not sure everyone would catch the one in 6.5 point typeface, in light green, disclaiming:

Note: Trainees must have hands-on training in the donning, doffing, and use of the Personal Protective Equipment and/or suplemental [sic] equipment required for their jobsite(s) in accordance with 29 CFR 1910.120. This is typically done at the jobsite by the student’s employer. Workers must then have at least three days of actual field supervision at the site under a trained, seasoned supervisor. The three days field experience under a trained, experienced supervisor is the responsibility of the student’s employer.

There are clearly advantages to online training of employees, particularly in respect to cost and time management. So what is reasonable to include in an online course, and how much time needs to be spent with a qualified trainer in person? My feeling is that 32 hours of online training covering the mandatory topics and eight hours of hands-on training is reasonable. The hands-on portion should include, at minimum, the following: donning and doffing personal protective equipment, working with monitoring equipment, practice/demonstration of sampling techniques, and a question-and-answer period.