Yes. Here is an excerpt from OSHA's October 20, 1999 letter of interpretation
concerning online refresher training:
"As a matter of policy, OSHA does not approve or endorse training programs. The employer, rather than the training provider, is ultimately responsible for ensuring that employees acquire the training and skills needed to perform their duties in a safe and healthful manner."
Once again, OSHA leaves the determination up to the employer. They do have concerns about online training. Specifically, OSHA believes hands-on training and access to a qualified instructor is extremely important for refresher training (and we agree). We suggest our course be augmented with additional "hands on" exercises such as a respirator fit-test, a review of a site-specific health and safety plan (HASP), and any other material or exercises deemed appropriate by the employer.