Computer-based bloodborne pathogen safety training

June 11, 1997

Ms. Anna E. Jolly, JD, CHMM
Circle Safety & Health Consultants, LLC
[Recipient address omitted]
Dear Ms. Jolly,

This letter is in response to your letter of May 27th to John Miles regarding the appropriateness of computer-based interactive training programs to satisfy required OSHA training. You expressed particular interest in its use for bloodborne pathogen training.

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. 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" programs in meeting their training requirements. Training under the bloodborne pathogen standard includes site-specific elements and should also to some degree be tailored to workers' assigned duties. In an effective training program, it is critical that trainees have an opportunity to ask questions where material is unfamiliar to them. In a computer-based program, this requirement may be met by providing a telephone hotline so that trainees will have direct access to a qualified trainer.

Equally important is the use of hands-on training and exercises to provide trainees with an opportunity to become familiar with equipment, personal protective equipment, and safe practices (e.g. glove removal) in a non-hazardous setting. It is unlikely that sole reliance on a computer-based training program is likely to achieve these objectives.

We hope that this information is helpful. If you have any further questions, please feel free to contact Craig Moulton of my staff et (202) 219-7380.

Sincerely,
Stephen Mallinger, Acting Director
Office of Health Compliance Assistance

[Requester letter reproduced on OSHA page; omitted here.]