Scenario: You are responsible for your company’s in-house first aid team, which consists of a number of employees trained in basic first aid and CPR to respond to medical emergencies in your facility. Having this program in place achieves compliance with requirements spelled out in OSHA’s General Industry Standard 1910.151 as well as your Permit Required Confined Space Program 1910. 146. Every two years, you hire an outside provider to conduct the First Aid and CPR training to train new members of your team and to keep your current members certified through one of the recognized providers programs.
Your two-year training is about due and you submit a request to your boss for permission to bring in the trainer to conduct the training. To your surprise, he asks you if there is a less expensive way to accomplish this training and suggests the team get their training through an online training provider he found on the internet at a much cheaper price.
Question: If your company elects to pursue this online training, will it meet OSHA’s intent of the basic First Aid and CPR requirements of OSHA Standards 29 CFR 1910.151 (medical services and first aid) and 1910.146 (permit-required confined spaces)?
Here is OSHA’s Response: In a Letter of Interpretation from OSHA dated August 2, 2012 to Ralph M. Shenefelt, Vice President of Strategic Compliance, OSHA attempts to answer this question with the following statement:
“Online training alone would not meet the requirements of these training standards. The word ‘train’ is defined as ‘[t]o make proficient with special instruction and practice,’ Webster’s II New Collegiate Dictionary, 1995, p. 1,169. These standards require training in physical skills, such as bandaging and CPR. The only way these physical skills can be learned is by actually practicing them. OSHA’s Best Practices Guide: Fundamentals of a Workplace First-Aid Program, 2006, p. 11, states that a first-aid training program should have trainees develop hands-on skills through the use of mannequins and partner practice. The guide may be accessed at www.osha.gov. Doctors and nurses receive hands-on training. However, the standards cited above do not require verification of competent performance, except as follows. The general industry confined space standard provides at 29 CFR 1910.146(k)(l)(i):
(k) Rescue and emergency services.
(1) An employer who designates rescue and emergency services, pursuant to paragraph (d)(9) of this section, shall:
(i) Evaluate a prospective rescuer’s ability to respond to a rescue summons in a timely manner, considering the hazard(s) identified;”
So as you can see, OSHA isn’t saying online training can’t be used for a portion of the training. However, the skills portion of the training must be administered in person by a qualified trainer.