Hazard Alert:

Summary

The rise of AI-enabled agents and tools, combined with the inadequacy of current training platforms, has rendered many online training systems incapable of confirming authentic participation. As a result, these systems can no longer be used to demonstrate compliance, are not legally defensible, and hold no risk-mitigation value.

With a simple command, new AI agents can log in to a training platform and complete all assigned courses on behalf of an employee. These agents can navigate lessons, answer all question formats, and generate completion certificates without any human involvement. As a result, all training records, compliance reports, and other metrics from unverified platforms have lost their credibility.

This technology is a significant advance from earlier AI tools. With no technical skill required, anyone can now bypass systems that don't actively confirm a user's presence. The core issue is not with individual workers, but with the failure of these training systems to keep up with modern technology.

Regulatory and Systemic Consequences

If a training platform cannot verify the learner, no defensible claim of training, related competency, or due diligence can be made.

Occupational Safety and Health Administration (OSHA) is aligned with jurisdictions including Australia, Canada, and the United Kingdom in clarifying that authentic worker participation is necessary for online courses to be considered training - regardless of completion records.

Industry standards like ANSI/ASSP Z490.1 (OSHA referenced/cited) and ANSI/IACET now explicitly require online learning platforms to confirm the identity and authentic participation of the individual, prohibiting the use of AI agents or similar tools.

Training that lacks these verification elements fails to meet legal and regulatory obligations and cannot function as a legitimate risk mitigation measure.

Recommended Organizational Actions

• Assess online training and assessment systems, whether internal or vendor-provided to their ability to confirm a learner's identity and ensure participation is not being performed by an AI agent.

• Implement technological safeguards to verify user identity and block AI circumvention tools.

• Document all training records to specify whether completion was verified or unverified.

• Benchmark all systems against current regulatory standards for your industry and jurisdiction.
  

Vulnerability Examples

The following examples, using the OSHA 10 certification, demonstrate this rapid technological progression and its impact on common training platforms. One or more of these vulnerabilities have been replicated in nine out of ten training systems reviewed.

Example 1:
An oscillating fan can satisfy "time in course" requirements.

Example 2:
An early GPT plugin can automatically answer knowledge-check questions.

Example 3:
A modern AI agent can login, navigate, and fully complete a training course without human presence, including bypassing participant verification.