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600 Introduction to Occupational Safety and Health
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When is Retraining Required?

When the employer has reason to believe any affected employee who has already been trained does not have the understanding and skill required by the PPE standard, the employer must retrain the employee.

Annual retraining is important to maintain PPE skills that are not used regularly.

Retraining is required but is not limited to situations where:

  • when the use of PPE is only required rarely;
  • changes in the workplace render previous training obsolete;
  • changes in the types of PPE to be used render previous training obsolete; or
  • deficiencies in an affected employee's knowledge or use of assigned PPE indicate that the employee has not retained the requisite understanding or skill

Online Training

According to an OSHA letter of interpretation (February 4, 2009) about online training, an employer may not rely solely on the use of an online or video training program when training the use of PPE.

According to OSHA, the trainee must be able to "don, doff, touch, feel and otherwise manipulate a particular piece of personal protective equipment that an employer may require or provide to protect their employees from injury or illness." To be considered adequate, online PPE training must also include a hands-on practice component so that the employee can practice using the employer's specific PPE.

PPE training must include a hands-on portion so employees can practice using the PPE.

Knowledge Check Choose the best answer for the question.

4-6. Why is online training, alone, not sufficient to meet OSHA's PPE training requirements?