Short Answer

Online training is in compliance with OSHA when conducted appropriately.

Now let’s examine what that means.

First, let's scope the Requirement

The interactive Q&A language appears specifically in the Bloodborne Pathogens (BBP) standard under: 29 CFR 1910.1030 (Bloodborne Pathogens Standard) — specifically subsection 1910.1030(g)(2)(vii)(N).

That subsection requires:

“An opportunity for interactive questions and answers with the person conducting the training session.”

Important clarification:

• This interactive Q&A requirement applies specifically to the Bloodborne Pathogens standard.
• Other OSHA standards do not contain this same “interactive questions and answers” requirement.

This means that other OSHA training lessons (for example, Hazard Communication, Workplace Safety, and similar topics) can generally be completed at the employee’s convenience without this specific interactive requirement.

What the Regulation Does Not Require

The BBP standard does not specify that the trainer must be physically present in the room where training is being conducted. It does not mandate classroom instruction, live group seminars, or in-person attendance.

The standard requires access to interaction—not physical presence. So long as a staff member can directly communicate with a qualified trainer for questions and answers, the standard is satisfied.

That interaction may occur through methods such as:

• Telephone
• Chat or electronic messaging
• Email that is immediately/directly responded to during the training session

OSHA Letters of Interpretation Confirm Online Training Is Permitted

OSHA has addressed this topic directly in formal Letters of Interpretation, which are considered official regulatory guidance. These interpretations confirm that computer-based or online training formats are acceptable—provided the interactive Q&A component is satisfied.

Two particularly relevant OSHA Letters of Interpretation include:

• OSHA Letter of Interpretation (January 17, 2008)
• OSHA Letter of Interpretation (June 26, 2003)

Across this guidance, OSHA explains that:

• Computer-based training may be used.
• The interactive requirement may be fulfilled through electronic means.
• Trainers do not need to be physically present.
• Employees must have an opportunity to ask questions and receive responses during the training session.

In the January 17, 2008 interpretation (see Question 2), OSHA confirms that remote communication methods can satisfy the interactive Q&A requirement.

In the June 26, 2003 interpretation (see Question 3), OSHA clarifies that a designated compliance officer within the practice may serve as the trainer—provided that person is knowledgeable in OSHA safety.

What Does “Knowledgeable in OSHA Safety” Mean?

OSHA does not provide a rigid definition of what constitutes being “knowledgeable.” However, OSHA indicates that qualifications may include factors such as:

• OSHA training
• Industry experience
• Relevant safety responsibilities within the practice

The key requirement is that the individual responding to questions is competent to provide accurate safety guidance. It does not require a specific instructor certification—it requires competency.

How This Applies in Practice

For online Bloodborne Pathogens training to comply with 29 CFR 1910.1030(g)(2)(vii)(N):

• A qualified trainer must be accessible.
• Employees must be able to submit questions.
• Responses must be available during the training session.

This can be accomplished by:

• A third-party training provider offering live support during business hours, or
• The practice’s OSHA compliance officer being available to answer questions while staff complete the BBP lesson.

If there is concern that interactive support was not available at the time the Bloodborne Pathogens lesson was completed, a staff member may retake that specific lesson during a time when qualified support is available.

Federal Conclusion

From a federal OSHA perspective:

• Online Bloodborne Pathogens training is permitted.
• In-person classroom delivery is not required.
• Interactive Q&A may be handled remotely.

When conducted appropriately, online OSHA training is compliant with 29 CFR 1910.1030(g)(2)(vii)(N).

State-Specific Consideration: Washington (WISHA)

For employers operating under Washington State’s OSHA program (WISHA), the Bloodborne Pathogens rule appears in: WAC 296-823-12005 (see subsection (m)).

It requires:

“An opportunity for interactive questions and answers with the trainer at the time of the training session.”

Immediately following this requirement, the regulation includes a note clarifying:

“This may be person-to-person, by telephone, or by email, as long as the employee can both ask and receive answers during the training session.”

This language explicitly permits remote Q&A, including phone or email-based interaction, provided employees can ask questions and receive responses during training.

Additionally, Washington Labor & Industries provides online Bloodborne Pathogens training materials here: WISHA/L&I Online Bloodborne Pathogens Training . A state agency would not publish training that fails to meet its own regulatory standards, further reinforcing that online BBP training with remote interaction is acceptable under WISHA.