If your training vendor tells you 40-Hour HAZWOPER training can be completed totally online....Think Again!

OSHA's General Industry Standard (referred to as the "catch-all regulation" when other regulations don't provide enough information or guidance)  specifies that the Employer, is responsible to insure employee training is comprehensive AND complies with OSHA regulations, recommendations and requirements. Don't EVER forget this....... your training vendor can sell you a "bill of goods" and YOU'RE STILL LIABLE, NOT THEM!

We suggest you read the following information BEFORE you purchase training from ANY OTHER COMPANY, especially one that claims they are "OSHA Compliant". When you finish, check out Compliance Solutions Online 40-Hour HAZWOPER. We are the ONLY online course that meets  or exceeds OSHA regulations, guidance, suggested training topics, interpretation letters AND offers Hands-On Training (in 57 cities!) as part of the course (that means at NO EXTRA COST).

OSHA HAZWOPER Guidance (also some of the most popular excuses your training vendor may use):

My 40-Hour HAZWOPER course be completed TOTALLY online, right?

I can meet the "Hands-On" training requirements during the 3-day site orientation, right?

OSHA Intrepretations can't add new requirements or change the law, RIGHT?

Don't take our word for it, get the information straight from OSHA's web site.

OSHA's guidance documents on this issue is very clear. From Richard E. Fairfax's (OSHA's Director of 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. In a computer-based program, this requirement may be accomplished through the provision of access to a telephone hotline at the time the training is being conducted so that trainees will have direct access to a qualified trainer at the time their questions are raised.

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.

In summary, OSHA believes that computer-based training programs can be used as part of an effective safety and health training program to satisfy OSHA training requirements, provided that the program is supplemented by the opportunity for trainees to ask questions of a qualified trainer, and gives trainees hands-on familiarity with protective equipment."

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Q. Would OSHA find it acceptable if the only experience that an employee gets in regards to the required hands-on training be during the three days of field experience at the hazardous waste site and not during the 40 hours of classroom instruction?

Answer: No. Supervised field experience is part of an employee's initial training, taking place after he or she has completed the off-site classroom instruction. Employees must be able to familiarize themselves with the equipment and field conditions under which they will be expected to work. The initial three days in the field under the supervision of another experienced employee combined with the required classroom instruction is required for new employees.

By the way: Some companies will  tell you their "Simulators" are BETTER than the real thing.  OSHA does not even mention simulators as being a sufficient method of training....let alone being "BETTER" than hands-on training! The next time you fly on a commercial airplane, ask the pilot if all their training was in a SIMULATOR! If a simulator is NOT good enough to bet YOUR life on, why would you bet your employees lives?

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My training company told me that I don't have to pay attention to "OSHA Interpretation Letters" because they "are not enforceable and they cannot place additional burdens on an employer".

Compare the above scenario to an OSHA Inspector seeing certificates from a reputable firm that WILL NOT DELIVER SUB-STANDARD TRAINING. Which audit do you want to be in?

OSHA issues Interpretation Letters  and Guidance to help you comply with standards and to keep your employees safe....Not to make your life miserable.

Ask yourself another question: Who has to pay the fine if OSHA issues a citation? Better yet: If an employee of yours is hurt or killed, who is the one that has to tell the employee's family? Who is going to pay the cost to represent you in court? Will it be that training company?

Finally, if you have a company that suggest you "skirt" or ignore OSHA regulations, what does this tell you about your training vendor? If your vendor's sales pitch is all about how to "avoid" OSHA regulations, Is this REALLY the company you want taking care of your employee health and safety requirements?

The bottom line is, these companies try and convince you to ignore OSHA for their  benefit....not yours. The REAL reason they want you to their course is they either don't have the resources to provide the training your employees need or they simply want to make a bigger profit..... at the expense of your employees safety.

DON'T RISK IT, IT'S NOT WORTH IT!

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