The question “can OHS training be online?” has two answers: yes and no. It depends on which training is meant and in what position the trainee works.
Forms of training under the regulation
The Polish Regulation of the Minister of Economy and Labour of 27 July 2004 on OHS training provides for four forms: instruction, course, seminar and guided self-study. Guided self-study is a form in which the participant learns from materials provided by the organiser (including over the internet), and the organiser provides the opportunity for consultation. This is the form under which online training falls.
What can be done online
Periodic training for employers and people managing employees, engineering and technical staff, OHS team members and administrative and office staff can take the form of a course, a seminar or guided self-study. For these groups, online training is therefore permissible, provided that it ends with a test and is documented.
General instruction as part of induction takes the form of instruction. The regulations do not require it to take place physically in one room, but it must be given by an authorised person (an OHS team member, the employer or a person performing the tasks of the OHS team) and must be confirmed by a signature on the induction training card.
What cannot be done online
On-the-job instruction is carried out at the workstation where the employee will work. Its purpose is to familiarise them with the specific hazards, machines and the safe way of doing the work in that place. This cannot be done remotely in compliance with the regulation.
Periodic training for blue-collar positions is carried out in the form of instruction. Guided self-study is not provided for this group, so a machine operator, warehouse operative or production worker should not complete periodic training solely over the internet.
How to document remote training
Whatever the form, periodic training ends with an exam, and its completion is confirmed by a certificate, a copy of which goes into the personnel file. With online training, it is worth also having a record of who used which materials and when, when they passed the test and with what score. This settles disputes during an inspection.
A practical solution: online, but on the shop floor
In a manufacturing company, the problem is not the law but logistics: a production worker has no work computer, and the instruction has to leave a trace. The ErgoFlow OHS app lets employees go through the material and the test on a computer, a phone or a kiosk on the shop floor, after logging in with a badge or a PIN; progress and the result are saved in the employee’s record. On-the-job instruction is still given by the supervisor at the machine, and the app keeps its date and signature. See OHS at ErgoFlow.
Legal status as of October 2026. This article is for information only and does not replace legal advice or the opinion of an OHS team.
