How Often is OSHA Bloodborne Pathogens Training Required?
OSHA bloodborne pathogens training is required prior to an employee being assigned a task in which there may be occupational exposure to blood or another potentially infectious material. Thereafter, training is required at least annually and whenever there is a material change that affects the employee’s potential exposure.
Like many standards in Subpart Z of the OSHA standards (Toxic and Hazardous Substances), the OSHA bloodborne pathogens standard is extremely comprehensive. The standard (§1910.1030) covers every type of engineering control to mitigate the threat of an employee acquiring an infection from contact with blood, other bodily fluids (including saliva), human tissues, or medical equipment.
How to Comply with the Bloodborne Pathogens Standard
To comply with the bloodborne pathogens standard, employers must compile a list of all job classifications in which some or all employees potentially have occupational exposure to bloodborne pathogens. They must also list all tasks and procedures in those job classifications, and develop engineering controls and work practices to eliminate or mitigate employee exposure.
The engineering controls should include hand washing/skin flushing facilities, sharps disposal units, and personal protective equipment (i.e., gloves) where considered necessary. The standard also requires employers to prohibit eating, drinking, smoking, applying cosmetics or lip balm, and handling contact lenses in work areas where there is a likelihood of occupational exposure.
Further requirements of the bloodborne pathogens standard include repairing or replacing damaged equipment, washing or disposing of personal protective equipment, and housekeeping controls to ensure spills, splashes, and spattering of hazardous substances are immediately contained and cleaned up by members of the workforce who have received OSHA bloodborne pathogen training.
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What does OSHA Bloodborne Pathogens Training Consist Of?
OSHA bloodborne pathogens training consists of training members of the workforce on the epidemiology and symptoms of bloodborne diseases and how they are transmitted from patient to provider. Thereafter, training must include information about the engineering controls and work practices developed by the employee to comply with OSHA. For example:
- Perform tasks and procedures safely
- Isolate or remove potential hazards
- Use sharps disposal containers
- Use cleaning and disinfecting equipment
- Correctly apply gloves, masks, and eye protection
- Properly wash off or flush contact with fluids
- Safely handle and dispose of bloodborne pathogens
- Report a spill, splash, or spatter
- Clean a spill, splash, or spatter.
There may be additional training requirements depending on the manner in which members of the workforce are exposed to infectious materials. For example, if a task includes patient handling, ergonomics training must be provided under the OSHA General Duty clause to mitigate the risks of musculoskeletal disorders and other physical injuries.
How Often is OSHA Bloodborne Pathogens Training Required?
OSHA bloodborne pathogens training is required prior to an employee being assigned a task in which there may be occupational exposure to blood or another potentially infectious material. Subject to state-approved OSHA Plans with more stringent requirements, refresher training is required at least annually or whenever there is a material change that affects employees’ potential exposure.
With regards to material changes, OSHA bloodborne pathogens training must be provided even if the procedure for carrying out a task is modified or if the coding of a hazard is amended. Training must also be provided when a member of the workforce progresses from (for example) handling non-infectious human pathogens to handling infectious human pathogens.
With regards to the provision of OSHA bloodborne pathogens training when training of a similar nature has already been provided, it is important to note OSHA has stated employees must receive OSHA bloodborne pathogens training regardless of prior education or training, but the standard allows employers to tailor training to each employee’s background and responsibilities.
If after reviewing the standard, you have questions about OSHA bloodborne pathogen training or how often it is required, you should seek professional compliance advice.
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