Question: OSHA law 29 CFR 1910.1030 (g)(2)(vii)(N) seems to require the "opportunity for interactive questions and answers with the person conducting the training session." Does this mean that online training is not in compliance with OSHA rules?
Answer:
The short answer is online OSHA training is in compliance with 29 CFR 1910.1030(g)(2)(vii)(N), when training is conducted appropriately. More information below:
- First, to help scope what we're talking about here. (g)(2)(vii)(N) is specifically talking about the Bloodborne Pathogens Standard (BBP). Other OSHA standards do not have this requirement of "an opportunity for interactive questions and answers". So all other lessons of the OSHA training can be completed whenever the staff member wants.
- Please note, the BBP standard does not specify that the trainer needs to be "physically" in the room where training is being conducted. So long as a staff member is able to directly communicate with a qualified trainer for Q&As (e.g. through telephone, chat, or even emails that are immediately/directly responded to), this is in compliance with the standard. (Reference #1, Question 2).
- Additionally, it is acceptable that your practice's OSHA compliance officer be available to take questions during training provided that person is knowledgeable in OSHA safety (Reference #2, Question 3). Please note that being "knowledgeable in OSHA safety" is not specifically defined in OSHA - OSHA training, experience in industry, etc. are all a part of someone being "knowledgeable".
- With Gamma Compliance, you do have access to qualified and authorized OSHA trainers during business hours. Completing specifically the bloodborne pathogen training lesson during these business hours or when your practice's OSHA compliance officer is available is in compliance with this requirement.
- If you are concerned that this may not have happened, you always have the option of having a staff member retake specifically that lesson of the training during business hours.
References:
- Letter of interpretation: https://www.osha.gov/laws-regs/standardinterpretations/2008-01-17
- Letter of interpretation: https://www.osha.gov/laws-regs/standardinterpretations/2003-06-26
- Please note, letters of interpretation are considered legal guidance from OSHA.
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