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If your
training vendor tells you 40-Hour HAZWOPER training can be completed
totally online....Think Again!
OSHA's General Industry Standard (the”catch all" when specific regulations don't provide
enough information or guidance) specifies that the Employer
is responsible for insuring employee training is comprehensive AND
complies with OSHA regulations and training recommendations. The
bottom line....... your training vendor can sell you a "bill
of goods" (or say whatever they want) and YOU ARE
LIABLE, NOT THE VENDOR.
OSHA's guidance documents on this issue is
very clear. From Richard E. Fairfax's (OSHA's
Director Enforcement Programs) August 16, 2004 letter on this issue,
he states:
"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.
OSHA urges employers to be wary of relying solely on generic "packaged"
training programs in meeting their training requirements since training
required under HAZWOPER includes site-specific elements which need
to be tailored to the individual worker's assigned duties.
Safety and health training may often involve
the presentation of technical material to audiences that typically
have not had formal education in technical or scientific disciplines,
such as in areas of chemistry or physiology. In an effective training
program, it is critical that trainees have the opportunity to ask
questions where material is unfamiliar to them.
For HAZWOPER training, equally important is the use of hands-on
experience and exercises to provide trainees with an opportunity
to become familiar with equipment and safe practices in a non-hazardous
setting. Many industrial operations, particularly hazardous waste
operations, involve complex hazardous tasks and exposures. Traditional
hands-on training ensures that workers are prepared to safely perform
their job assignments. The purpose of hands-on training (i.e., in
the donning and doffing of PPE) is two-fold: first, to ensure that
workers have an opportunity to learn by practical experience and
second, to assess whether workers have mastered the necessary skills.
It is unlikely that sole reliance on a computer-based training program
will accomplish these objectives
Get current information
straight from OSHA's web site.
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