Workplace Safety and Health: Information on OSHA Training for Workers on Workplace Hazards
Published: 2017-02-07T00:00:00

Fast Facts:

Highlights:
section_title: Why GAO Did This Study
paragraphs: In fiscal year 2016, approximately 900,000 workers were trained through OSHA's Outreach Training Program, the agency's primary mechanism for training workers on the basics of occupational safety and health. OSHA offers this training through OSHA-authorized in-person and online training providers. GAO was asked to review OSHA's administration of the program.
GAO examined (1) the extent to which the program aligns with leading practices in designing an effective training program, (2) the process for documenting successful completion of the training and whether internal controls are in place to assure completion is accurately documented, and (3) how OSHA oversees training providers and assesses the results of the program. GAO compared OSHA's design and evaluation efforts for its training program with leading practices in GAO's training guide (GAO-04-546G) and federal internal control standards, and analyzed fiscal year 2012-2016 OSHA data (the most recent available) on time frames for processing completion card requests from online training providers. GAO also interviewed all nine online training providers and five in-person training providers, selected for having a high number of participants in fiscal year 2015, as well as OSHA officials.
GAO is not making recommendations in this report.
section_title: What GAO Found
paragraphs: The Department of Labor's Occupational Safety and Health Administration's (OSHA) Outreach Training Program–which offers training on job hazard recognition and avoidance–reflects many of the attributes of a well-designed training program identified in GAO's training guide. OSHA is not required to follow GAO's training guide; however, the program's design reflects at least one indicator for six of the seven attributes of a well-designed training program GAO has identified. For example, OSHA used an appropriate mix of centralized and decentralized approaches by developing core learning objectives and content requirements for the courses but allowed training providers to modify the curriculum to meet the specific needs of their audience. In addition, OSHA officials told GAO that they took into account the leading causes of worker deaths and the most common workplace safety and health violations to determine topics to be covered in the training.
OSHA documents successful course completion differently depending on whether training was delivered in-person or online, but it uses the same controls to prevent fraudulent completion cards from being issued. OSHA officials and the training providers GAO interviewed reported using several checks to prevent fraudulent completion cards from being issued, such as verifying course completion through automated and manual processes and comparing the number of cards requested to the number of registered students. Although OSHA does not require workers to complete Outreach Training, some workers may need to show proof of completion to satisfy requirements by their states, municipalities, employers, or unions. To obtain completion cards, Outreach trainers who deliver in-person training submit course information through a web-based system, while online training providers mail documentation to OSHA. OSHA processed 91 percent of the card requests from online training providers within 2 weeks, which is within the 30-day deadline OSHA has set for itself, according to GAO's analysis of OSHA data. OSHA officials reported that they plan to allow all training providers to request completion cards electronically, but the agency has not established a timeline for implementing this new process. According to OSHA officials, the agency is taking steps to modify its process for selecting online training providers and plans to incorporate electronic requests for completion cards into the new process.
OSHA oversees the performance of training providers by routinely collecting and assessing data and investigating complaints and has taken some steps to assess the results of the program. Specifically, OSHA collects data from the training providers to help ensure that the training meets the program requirements and that the trainers are delivering the Outreach Training courses as intended. OSHA also investigates complaints it receives about training providers, including issues such as the trainer not spending enough time on required safety topics. To assess program results, OSHA tracks the number of workers who take the Outreach Training courses to measure the reach of the program. According to OSHA data, from fiscal year 2000 to fiscal year 2016, the number of workers trained more than quadrupled from 200,522 to 900,010. OSHA also receives test results and student evaluations of the courses from some of the Outreach Training providers.

section_title: Letter
paragraphs: In 2014, approximately 4,800 workers died on the job, and employers  reported about 3 million nonfatal work-related injuries, according to data  collected by the Department of Labor (DOL). DOL’s Occupational Safety  and Health Administration (OSHA) is responsible for protecting the safety  and health of the nation’s workers under the Occupational Safety and  Health Act of 1970 (OSH Act). Ensuring that workers are properly trained  in recognizing and avoiding workplace hazards is an important  component in establishing and maintaining a safe and healthy workplace.  In fiscal year 2016, approximately 900,000 workers were trained in job  hazard recognition and avoidance through OSHA’s Outreach Training  Program. In-person Outreach Training is provided to workers by  Outreach trainers, safety professionals who have taken train-the-trainer  courses at OSHA Training Institute Education Centers (Education  Centers), which are a national network of nonprofit organizations  authorized by OSHA to deliver various types of occupational safety and  health training. Since 2001, OSHA has also allowed Outreach Training  courses to be delivered online through authorized vendors. Participation  in the program has grown substantially over time and although most  workers take the training in-person, workers are increasingly taking the  courses online. You asked us to review OSHA’s administration of the  program, including the in-person and online training, and to determine  how OSHA assesses the results of the program.
This report examines (1) the extent to which OSHA’s Outreach Training  Program aligns with leading practices in designing an effective training program, (2) the process OSHA uses to document students’ successful  completion of the training and the extent to which internal controls are in  place to assure completion is accurately documented, and (3) how OSHA  oversees training providers and assesses the results of the program.
To address all of our objectives, we interviewed OSHA officials;  representatives from all nine online training providers; and  representatives from five Education Centers, selected because they had  among the highest number of Outreach Training participants of all 27  Education Centers in fiscal year 2015. Together, the 5 Education Centers  accounted for 46 percent of workers trained in-person that year. We also  observed three Outreach Training courses—two in-person and one  online. Our observations from these training courses are intended to be  illustrative, and are not generalizable. To determine the extent to which  the design of the Outreach Training Program reflects leading practices,  we compared the information obtained through interviews with OSHA  officials and agency documentation to practices identified in GAO’s guide  for assessing training and federal internal control standards. While  GAO’s guide for assessing training is intended to help federal agencies  review training and development programs for their employees, the  attributes of effective training programs identified in the guide are derived  from sources that are generally applicable to training and can be used to  review a particular agency program or activity. To examine the process  for documenting successful course completion, we reviewed (1) OSHA’s  policies and procedures for issuing course completion cards and (2) other  information obtained from OSHA, the online training providers, and the  five Education Centers. We also analyzed the latest OSHA data available  at the time of our review from fiscal years 2012 through 2016 on the  timeframes for processing requests from online training providers for  course completion cards. We assessed the reliability of OSHA’s card  processing data by (1) performing electronic testing of required data  elements, (2) reviewing existing information about the data and the  system that produced them, and (3) interviewing agency officials  knowledgeable about the data. Based on these reviews, we determined  that the data were sufficiently reliable for our purposes. To determine how  OSHA oversees Outreach Training providers and assesses the results of  the program, we reviewed OSHA’s reporting requirements for training  providers, monitoring procedures, and agency monitoring reports. We  also compared OSHA’s efforts to training evaluation practices in GAO’s  training guide (GAO-04-546G) and federal internal control standards.
We conducted this performance audit from February 2016 to February  2017 in accordance with generally accepted government auditing  standards. Those standards require that we plan and perform the audit to  obtain sufficient, appropriate evidence to provide a reasonable basis for  our findings and conclusions based on our audit objectives. We believe  that the evidence obtained provides a reasonable basis for our findings  and conclusions based on our audit objectives.
subsections: section_title: Background
paragraphs: OSHA is the federal agency responsible for administering the  Occupational Safety and Health Act of 1970, as amended (OSH Act),  which was enacted to assure safe and healthful working conditions for the  nation’s workers. As authorized by the act, OSHA sets and enforces  occupational safety and health standards, which are regulations that set  forth specific safety and health requirements with which covered  employers must comply. Among its other responsibilities under the OSH  Act, OSHA is also required to provide for the establishment and  supervision of training programs to help workers and employers  recognize, avoid, and prevent workplace safety and health hazards.
The Outreach Training Program is the agency’s primary way to offer  training for workers in the basics of occupational safety and health,  according to OSHA. Outreach Training includes voluntary 10-hour and  30-hour safety courses designed to provide basic hazard awareness  training for workers in construction, maritime, and general industry, and a  15-hour course for workers at disaster sites. The training covers how to  recognize and prevent hazards on a jobsite, workers’ rights, employers’  responsibilities, and how to file a complaint. The 30-hour courses are  intended to provide more in-depth training to workers who have some  safety responsibility. Workers that successfully complete an OSHA  Outreach Training Program course receive a student course completion  card. The student course completion cards in Construction, General  Industry, and Disaster Site do not have an expiration date; however, the  Maritime Outreach Training student course completion cards expire 5  years after completing the training.
While OSHA does not require workers to take its Outreach Training  courses, depending on their jobs and where the workers are located, they  may be subject to other requirements to show an OSHA course  completion card to demonstrate they completed the training. For  example, some states, municipalities, unions, and employers may require  workers to take an OSHA Outreach Training course as a condition of  employment for certain jobs, and OSHA maintains a list of states and  municipalities that have such a requirement. According to OSHA’s list,  seven states (Connecticut, Massachusetts, Missouri, Nevada, New  Hampshire, New York, and Rhode Island), and three municipalities  (Miami-Dade County, New York City, and Philadelphia) require certain  workers to take some form of OSHA Outreach Training or an equivalent  training. For example, all of these states and municipalities require certain  workers on public construction projects to take a 10-hour construction  safety course. Some, including Nevada and Philadelphia, also require this  training for workers on private construction projects.
subsections: section_title: Types of Outreach Training Providers
paragraphs: Outreach Training courses are delivered by OSHA-authorized external  training providers that receive no funding from OSHA, but instead, rely on  tuition and fees from training participants to cover the cost of the training.  The types of training providers include Education Centers, which train  Outreach trainers to deliver in-person Outreach Training courses to  workers, and online training providers.
Education Centers: OSHA has nonfinancial cooperative agreements  with 27 Education Centers–which are typically universities–to provide  occupational safety and health training to workers and employers on  behalf of OSHA. The Education Centers have two main roles under  the Outreach Training Program: (1) conduct in-person train-the-trainer  courses to qualified individuals interested in becoming authorized  Outreach trainers; and (2) act as an authorized training organization  for the Outreach trainers by monitoring Outreach trainers through  records audits and training observations and by processing course  completion cards that Outreach trainers request on behalf of the  workers who take their courses. OSHA selected the Education  Centers through a formal competitive application process. Successful  applicants entered into 5-year nonfinancial cooperative agreements  with OSHA.
Outreach trainers: For in-person training, Education Centers  authorize Outreach trainers to provide the training to workers. To  become an authorized Outreach trainer, individuals must meet  industry safety experience requirements, complete a training course  on the applicable OSHA standards, and successfully complete a train- the-trainer course at one of the Education Centers. Outreach trainers  are authorized to provide in-person training to workers for 4 years  from the date that the trainer course is completed and must  successfully complete an update course at an Education Center to  maintain authorization. Currently, there are approximately 30,000  authorized Outreach trainers, according to OSHA officials.
Online training providers: Online training is provided by nine OSHA- authorized online training providers, including eight companies and  one Education Center. OSHA used a multi-phase process to select  the current online training providers that is described in OSHA  guidance. The guidance provided the requirements for establishing  an online Outreach Training course and a process for OSHA  authorization. The phases of the process included: (1) submission of a  description of the online training program, target audience, and  expected impact of the program; (2) submission of a detailed written  description of the online training plan; (3) self-verification audit where  the online training provider reviews the training against OSHA’s  guidance; and (4) OSHA’s review of the completed online training to  verify that the program is consistent with OSHA’s guidance.
In recent years, OSHA has attempted to change its process for selecting  the online training providers, but those attempts have been challenged in  court. In 2011 and 2014, the agency issued public solicitations, intending  to enter into nonfinancial cooperative agreements or contracts with  selected providers. Both solicitations were found to have procedural  deficiencies by the U.S. Court of Federal Claims after online training  companies challenged them in court. According to OSHA officials, the  agency has revised the solicitation to address the court rulings, but no  date has been set for issuing the revised solicitation. Currently, the nine  online training providers provide OSHA Outreach Training under their  2009 authorization.
section_title: Program Participation
paragraphs: Participation in the Outreach Training Program has grown substantially  over time. The number of workers trained more than quadrupled from  200,522 in fiscal year 2000 to 900,010 in fiscal year 2016. The vast  majority of participants take the courses in-person; however, the number  of participants taking the courses online has increased in recent years  (see fig. 1). In fiscal year 2016, 70 percent of participants took the  Outreach Training courses in person, and 30 percent took the courses  online. The number of participants taking the courses online increased  from 19 percent in fiscal year 2011 to 30 percent in fiscal year 2016.
The courses tailored to the construction industry are the most popular. In  fiscal year 2016, about 75 percent of the Outreach Training participants  took the construction courses, and 24 percent took the general industry  courses (see fig. 2).
section_title: OSHA’s Outreach Training Program Reflects Attributes of a Well-Designed Training Program
paragraphs: OSHA’s Outreach Training Program reflects attributes of a well-designed  training program. GAO’s training guide identifies attributes of a well- designed training program and suggests the kinds of documentation to  look for that indicate that a training program has a particular attribute in  place. OSHA is not required to follow GAO’s training guide, however,  we found that the program’s design reflected at least one indicator for six  of the seven attributes of a well-designed training program described in  the guide (see table 1).
OSHA took steps to design the Outreach Training Program so that  workers receive consistent and quality training by using data to identify  the content of the training, developing training materials, and issuing  detailed requirements for training providers. According to OSHA officials,  the content of the training was selected after the agency reviewed data on  the leading causes of worker deaths and the most frequently cited OSHA  standards. OSHA also developed training materials that training  providers can use, including presentations, lesson plans, fact sheets, and  tests. In addition, OSHA developed detailed requirements regarding the  content and delivery of the training that apply to all Outreach Training  providers to improve the quality of the courses and ensure the integrity of  its authorized trainers. Specifically, in 2011, OSHA replaced its previous  program guidelines with a revised policy document establishing  requirements that apply to all Outreach Training providers, including in- person and online training providers. OSHA issued general Outreach  Training Program Requirements and separate Industry Procedures for the  Construction, General Industry, Maritime, and Disaster Site courses. The  requirements and industry-specific procedures identify the learning  objectives for the courses, the topics that must be covered, and the  amount of time training providers must spend on each topic, among other  things. OSHA most recently revised the Outreach Training Program  Requirements and industry-specific procedures in January of 2017.
OSHA used a combination of centralized and decentralized approaches  to design the Outreach Training Program. GAO’s training guide suggests  agencies consider the advantages and disadvantages of using  centralized and decentralized approaches to designing training programs.  Centralizing design can enhance consistency of training content whereas  a decentralized approach to training design can enable agencies to tailor  training programs to better meet the unique needs of the intended  audience. OSHA used a combination of approaches by centrally setting  the learning objectives and establishing detailed content requirements,  while also allowing training providers to supplement the curriculum to  meet the specific needs of their audience. For example, while OSHA  requires all Outreach Training courses to include 2 hours of introductory  information about OSHA, training providers have some flexibility to  develop the rest of the curriculum as long as they cover the required  topics and meet the time requirements. Table 2 provides a summary of  OSHA’s topic and time requirements for the 10-hour construction  Outreach Training course.
In addition, although OSHA does not require any accreditation for  Outreach Training providers, OSHA’s Directorate of Training and  Education, which designed the Outreach Training Program, and several  of the online training providers, reported that they are accredited by the  International  Association for Continuing Education and Training (IACET).  IACET accreditation involves an audit of the organization’s training  program that benchmarks the organization against a national standard  called the IACET Standard for Continuing Education and Training.  IACET officials review the training provider’s application and document  that the standard is being followed by the organization and that the  attestations in the application are accurate by conducting a site visit.  IACET-accredited training providers must demonstrate that they have  processes in place to ensure that the individuals involved in training  design are qualified and that the content and instructional methods used  are appropriate for the learning objectives of the training, among other  things. According to OSHA officials, having OSHA’s Directorate of  Training and Education become IACET-accredited as a continuing  education provider demonstrates the agency’s commitment to high  standards for the agency’s training programs. The Education Centers we  interviewed had a different form of accreditation associated with their  universities.
section_title: Outreach Training Providers Use Automated and Manual Processes and Controls to Document Students’ Successful Course Completion
paragraphs: To obtain course completion cards, which training providers distribute to  workers who complete the training, training providers must submit class  documentation through either an automated or paper-based process.  Outreach trainers–who deliver in-person training to workers–request  cards by submitting class documentation electronically through a web- based system to the Education Center where the trainer was authorized.  If approved, the Outreach trainers are sent wallet-sized plastic cards for  the workers, each with a Quick Response (QR) code that can be scanned  with a smart phone, allowing employers and workers to verify the  authenticity of the card. In contrast, online training providers mail class  documentation, such as student names, course completion dates, test  results, and student evaluations of the courses, to OSHA to obtain cards  for the workers who take the training online. If approved, the online  training providers are sent wallet-sized paper cards for the workers. The  online training provider then prints the student names on the paper cards  and distributes them to the workers (see fig.3).
OSHA typically processed the course completion cards within 2 weeks of  receiving the request from the online training providers, according to our  analysis of OSHA data. OSHA has 30 days to process course  completion cards after receiving an online training provider’s request for  cards, according to an internal deadline set by OSHA. In our analysis of  OSHA fiscal year 2012-2016 data, we found that OSHA took 7 days on  average to process the cards, and the processing time ranged from  processing the cards the day OSHA received the request to 51 days.  Two-thirds of the card requests were processed in a week or less, and 91  percent were processed within 2 weeks.
However, six of the nine online training providers we interviewed said  OSHA’s paper-based system for processing course completion cards  contributed to delays in issuing cards to workers. For example, one online  training provider said it mails OSHA between 200 and 300 pages of class  documentation on a bi-weekly basis and it takes OSHA up to 4 weeks to  mail the cards back to them. Three of the nine online training providers  we interviewed gave examples of how lengthy processing times can  negatively impact workers. One online training provider that serves  younger workers said delays can be problematic, especially at the end of  the school semester, because if the student does not get the course  completion card in time, he or she may not have the required documents  needed to start their summer job. Another online training provider said  that waiting for OSHA to process the cards causes anxiety for many  students, as 3 or 4 weeks is a long time to wait for something required  before they can get a job. A third online training provider said there have  been instances where their students could not start working on the job  site because the student did not have their course completion card and  the employer or union refused to accept the online training provider’s  certificate of completion. While online training providers have noted these  issues, the two national organizations we interviewed that represent  employers and unions said that they have not received complaints from  workers regarding delays in getting their course completion cards or that  delays affected their ability to start working at their job site.
Differences in the process for issuing course completion cards stem from  the history of the program, according to OSHA officials. When OSHA  began partnering with the Education Centers to conduct OSHA Training  Institute courses in 1992, the agency required individual Outreach trainers  to request course completion cards for workers through the Education  Center where they received authorization to serve as trainers. According  to OSHA officials, in 2001, when OSHA began allowing the 10- and 30- hour construction and general industry Outreach Training courses to be  delivered in an online format, OSHA decided to serve as the authorizer  for the online providers.
OSHA officials told us that they are planning to allow the online training  providers to request cards electronically by having the Education Centers  take over processing the course completion cards for the online training  providers, but OSHA has not established a timeline for implementing this  new process. According to OSHA officials, the agency plans to include a  process for electronically requesting course completion cards in  conjunction with the revised solicitation for selecting the online training  providers that OSHA is finalizing. OSHA also intends to make the plastic  cards available to workers who take the courses online. Having the  Education Centers issue course completion cards to online providers may  help to speed the time for issuing these cards to workers. However, the  online training providers we interviewed generally said that they believe  that they could issue the cards more quickly if they issued the cards  themselves. OSHA officials told us they considered allowing the online  training providers to process and print their own OSHA cards but decided  not to because they want to limit the number of organizations that have  access to the course completion cards.
Training providers and OSHA officials reported using automated and  manual checks to help ensure that cards are requested only for the  students who successfully complete the courses and that the courses  meet OSHA’s Outreach Training Program requirements. Both the  Education Centers and online training providers reported using  information systems that automatically check whether the students have  taken courses that met OSHA requirements, such as spending the  minimum amount of time on specific topics. Some of the online and in- person training providers reported also using staff to manually verify the  information in the class documentation submitted to obtain course  completion cards. The online training providers reported using user  names and passwords to verify that the person registered for the course  is the person completing the course. In addition, some of the online  training providers reported that they are capable of using biometric data,  such as voice recognition or keystroke analysis, to authenticate students.  OSHA manually compares the number of cards requested by the online  training providers to the number of student names listed in the class  documentation and logs the unique course completion card numbers into  a spreadsheet.
Use of internal controls in the course completion card process is  important to protect the integrity of the program. OSHA works with DOL’s  Office of Inspector General to investigate and address fraudulent activity.  According to OSHA officials, there have been relatively few cases of fraud  in the program. OSHA refers fraudulent activity to DOL’s Office of  Inspector General, and trainers caught falsifying information may be  subject to criminal prosecution. DOL’s Office of Inspector General  investigated four cases of fraud involving OSHA training over the last 3  years, according to Office of Inspector General officials. Examples of  fraud cases they identified include an Outreach trainer selling course  completion cards to construction workers without providing the training  and an individual conspiring with an Outreach trainer to sell fraudulent  OSHA course completion cards.
section_title: OSHA Oversees Training Providers by Collecting Data and Investigating Complaints, and Has Taken Some Steps to Assess Program Results OSHA Oversees Training Providers by Routinely Collecting and Assessing Data and Investigating Complaints
paragraphs: OSHA oversees the in-person training providers on an ongoing basis by  collecting and assessing data from the Education Centers, including:
Course information: OSHA collects data on the train-the-trainer  courses the Education Centers deliver to individuals interested in  becoming authorized Outreach trainers, including the names of the  courses presented each month, training locations and dates,  instructor names, total students, total instructional hours, and test  results.
Course completion card processing: OSHA collects data on the  number of course completion cards the Education Centers process  each month for their authorized Outreach trainers.
Monitoring activities: OSHA collects data on the number of record  audits and training observations the Education Centers conduct on  their authorized Outreach trainers to check that the in-person training  delivered to workers complies with OSHA’s Outreach Training  Program requirements and procedures.
OSHA assesses the Education Centers’ performance on 11 performance  elements (see table 3), which relate to the Education Centers’ Outreach  Training Program responsibilities and their other responsibilities outlined  in their nonfinancial cooperative agreements with OSHA.
OSHA uses the data it collects from the Education Centers to assess the  extent to which the Education Centers are meeting their performance  goals in an annual appraisal. OSHA rates the Education Centers on a three-point scale of “outstanding,” “satisfactory,” or “area for  improvement” for seven performance elements and on a two-point scale  of “satisfactory” and “area for improvement” for the remaining four  performance elements. For example, in OSHA’s appraisals for fiscal  year 2015, OSHA rated 22 of 27 Education Centers an “outstanding” or  “satisfactory” rating on their Outreach trainer monitoring and identified this  as an “area of improvement” for 5 Education Centers because they did  not take certain actions, such as conducting enough records audits and  training observations (see fig. 4).
OSHA follows up with the Education Centers that have received “area for  improvement” ratings to ensure they are taking corrective action. OSHA  checks whether corrective actions are implemented by conducting  quarterly course documentation audits, annual conference calls, and  periodic on-site audits, as well as by developing mid-year status reports.  In addition, the program coordinator for the OSHA Training Institute  Education Center Program interacts with the Education Centers  throughout the year to ensure they are meeting performance goals,  according to OSHA officials.
OSHA also investigates complaints it receives about Outreach trainers  from the general public, referrals from the Education Centers based on  their Outreach trainer monitoring, and requests by other OSHA regional  offices. OSHA investigates allegations that an Outreach trainer may not  be in compliance with OSHA’s Outreach Training Program Requirements  and allegations of potential fraud. For example, OSHA may investigate  cases where an Outreach trainer fails to respond to audit requests from  an Education Center or fails to provide training that meets OSHA’s  requirements, such as spending enough time on required topics. OSHA  will notify the Outreach trainer of its findings from the investigation and  allow the trainer 15 days to address the findings identified in the  notification. If the trainer does not respond within this timeframe, OSHA  may suspend the trainer indefinitely  until a response is received. The  trainers can appeal OSHA’s initial decision. If there is an appeal, OSHA  will review it and make a final decision, which may result in the Outreach  trainer being subjected to disciplinary actions, including probation,  suspension, or revocation of the Outreach trainer authorization. As of  October 2016, 107 Outreach trainers, which is less than 1 percent of the  approximately 30,000 Outreach trainers, have had their status as  authorized Outreach trainers suspended or revoked by OSHA as a result  of failing to comply with the Outreach Training Program requirements and  procedures.
OSHA officials said that they oversee the online training providers by  collecting updated course information twice per year and investigating  any complaints about the training. In 2009, OSHA required that online  training providers complete an initial multi-phase process to develop  online Outreach Training courses that meet OSHA’s requirements.  According to OSHA officials, after they initially approved the online  training providers, OSHA monitoring has consisted of responding to  complaints about the training, requiring online providers to submit  updated information on their courses twice per year, and requiring that  providers self-certify twice per year that their training meets OSHA’s  requirements. OSHA investigates complaints about the online training  providers by first sending them a notification letter describing the issue.  Examples of issues OSHA has investigated include cases where an  online provider incorrectly advertised the courses or offered the training  outside of OSHA’s geographic jurisdiction. The online provider has 15  days to respond to OSHA, and if OSHA determines they have violated  applicable requirements, OSHA may suspend, terminate, or put them on  probation. Online providers who are placed on probation are required to  submit monthly self-certifications to OSHA that their program is in  compliance with OSHA’s online training guidance. OSHA did not establish  a performance assessment process for online training providers when the  current providers were selected in 2009, but according to officials, the  agency is in the process of finalizing a public solicitation for a new model  for authorizing online providers that they said will include new  requirements for the providers. OSHA officials said that having these new  requirements in place for the online training providers will improve the  providers’ understanding of what is expected of them and help OSHA  gather additional information on the providers’ performance.
subsections: section_title: OSHA Tracks the Number of Workers Trained and Requires Some Training Providers to Conduct Evaluation Activities
paragraphs: OSHA tracks the number of workers who take the Outreach Training  courses to measure the reach of the program. OSHA measures the  results of the Outreach Training Program by setting yearly targets for the  number of workers trained and uses these data to report its progress in  meeting its strategic goal of improving workplace safety and health. While  the agency missed its target for fiscal years 2011 and 2012, it exceeded  its targets for fiscal years 2013 through 2016 (see fig. 5). OSHA obtains  information on the number of workers trained from the Education Centers  and online training providers.
OSHA also requires some of the Outreach Training providers to evaluate  the training they provide using the Kirkpatrick model—a commonly  accepted model for evaluating training—which is endorsed by the Office  of Personnel Management in its training evaluation guidance and GAO’s  training guide. The Kirkpatrick model consists of a four-level approach  for soliciting feedback from training course participants and evaluating the  impact the training had on individual development, among other things.  The Education Centers and the online training providers are required to  report on the first two of those levels (see fig. 6) and are encouraged to  conduct the other two higher levels of evaluation of the courses they  deliver. Individual  Outreach trainers, who provide in-person training to  workers, are not required to assess the training they deliver.
OSHA officials said they decided not to require Outreach trainers  conducting in-person training to test student knowledge or use student  evaluations—even though this is how the vast majority of training in the  program is delivered—because they did not want these activities to take  away from instructional time. According to OSHA officials, when  delivering 10- and 30-hour Outreach Training courses in the classroom,  trainers have the ability to ask questions to encourage student  participation and use activities to verify that the transfer of learning has  occurred. However, due to the less interactive nature of the online training  courses, OSHA determined that the online 10- and 30-hour classes  require a testing component to ensure the students understand the  material provided. According to OSHA officials, OSHA also requires  testing for the Education Centers’ train-the-trainer courses to ensure the  trainers have mastered the course content and are able to effectively  teach the Outreach Training curriculum to workers.
OSHA has taken some steps to assess the results of some of the  evaluation information it collects and plans to make greater use of  evaluation information it collects from the Education Centers in the  future. For the in-person train-the-trainer courses that the Education  Centers deliver, OSHA receives test results and copies of student  evaluations. The Education Centers use a standard student evaluation  form that can be electronically processed by OSHA. OSHA then  automatically tabulates the information in the student evaluations and  returns them to the Education Centers so that they can use them to make  improvements to their courses. According to OSHA officials, OSHA  reviewed a sample of the student evaluations and found positive results  through these reviews. Beginning in fiscal year 2017, OSHA officials said  they plan to begin assessing the student evaluation results from the train- the trainer courses as part of the annual appraisal process for Education  Centers by adding a related performance measure to its expectations for  the Education Centers. For the online training, OSHA receives test results  and copies of student evaluations, which ask the students to identify the  extent to which the training will help them better identify hazards and if  they had any technical problems accessing the training, among other  things. According to OSHA officials, they have not used this information to  assess the results of the Outreach Training Program because the agency  receives paper copies of the results in different formats, and the agency  does not have the resources to analyze the information in its current  format.
section_title: Agency Comments
paragraphs: We provided a draft of this report to DOL for its review. DOL did not  provide formal comments and did not have any technical comments.
As agreed with your office, unless you publicly announce the contents of  this report earlier, we plan no further distribution until 30 days from the  report date. At that time we will send copies of this report to the  appropriate congressional committees, the Acting Secretary of Labor, the  Deputy Assistant Secretary for OSHA, and other interested parties. In  addition, this report is available at no charge on the GAO website at  http://www.gao.gov.
Please contact me on (202) 512-7215 or at bawdena@gao.gov if you or  your staff have any questions about this report. Contact points for our  Offices of Congressional Relations and Public Affairs may be found on  the last page of this report. Key contributors to this report are listed in  appendix I.
section_title: Appendix I: GAO Contact and Staff Acknowledgments
subsections: section_title: GAO Contact
section_title: Staff Acknowledgments
paragraphs: In addition to the contact named above, Mary Crenshaw (Assistant  Director), Cathy Roark (Analyst-in-Charge), Hiwotte Amare, Deborah  Bland, Carol Bray, David Chrisinger, Scott Coleman, Sarah Cornetto, Cliff  Douglas, Holly Dye, Sharon Hermes, Sheila McCoy, Jonathan McMurray,  Jean McSween, David Moser, Mimi Nguyen, Stacy Spence, and Bill  Woods made significant contributions to this report.