Ten FAQs on Bloodborne Pathogens Training

So far this fiscal year, OSHA has cited the training regulation for bloodborne pathogens over 200 times! That may be because 29 CFR 1910.1030 (and its training requirement) is one of the most confusing OSHA standards. Once you discover the standard applies, you may be left scratching your head. 

If you are a general industry or shipyard employer that has one or more workers with “occupational exposure,” you fall under §1910.1030. Occupational exposure means skin, eye, or mucous membrane contact with blood or “other potentially infectious materials.” It also includes contact with those materials by piercing mucous membranes or the skin with needlesticks, cuts, bites, etc.

The contact must be reasonably anticipated and relate to an employee’s duties to be regulated by the standard. For example, if you designate an office worker to clean up blood spills or perform first aid involving blood-related injuries of co-workers, that worker has occupational exposure.

Below are ten frequently asked questions on bloodborne pathogens training:

1. Which workers must be trained?

In general industry and shipyards, you must train each worker with occupational exposure. While construction workers are not covered by §1910.1030, they must have training per 29 CFR 1926.21.

2. What about part-time and temporary workers?

It makes no difference whether a worker is full-time, part-time, temporary, or contracted. A worker needs training if he or she has occupational exposure.

3. When must you provide bloodborne pathogens training?

General industry and shipyard workers with occupational exposure must receive training:

• Initially, prior to assignments where occupational exposure may occur;
• At least annually thereafter; and
• When changes like modified or new tasks/procedures affect a worker’s occupational exposure.

Any training and retraining must be provided during that worker’s working hours.

4. What if your worker misses the annual retraining date?

Annual training means workers must be retrained at least once every 12 months, within 365 days. It does not need to be done on the exact anniversary date, but it should be provided on a date reasonably close to that date. If you cannot complete the annual training by that date, keep a record explaining why the training is delayed and when the training will be provided.

5. What qualifications are required for the trainer?

You need a trainer who knows the subjects covered by the 14 training elements in the standard. This trainer must also understand how the elements relate to your workplace. During an inspection, an OSHA officer may look at the courses, degrees, or work experience of your trainer, if that officer finds any problems in your training program.

6. Does the trainer need to be present during training?

Direct access is required, but the trainer does not need to be in the same room. OSHA will allow a trainer to be accessible via a telephone or email, as long as the trainer is available to answer questions at the very same time they arise. There cannot be any delays, or it won’t be considered direct access.

7. Is computer- or video-based training sufficient?

Computer- and video-based training are good training tools. However, training in those formats alone is not enough because §1910.1030 requires trainees to have a chance to ask and get answers to questions. You must also supplement computer or video training with site-specific information. Examples include information about the location of your written plan and steps to take if an exposure incident occurs.

8. Who has responsibility to train temporary workers?

As joint employers, both the staffing agency and the host employer are responsible for ensuring that the temporary worker is properly trained. The two may divide the training responsibility. Generally, the staffing agency is responsible for giving generic bloodborne pathogens information and training, while the host employer is typically responsible for giving site-specific training on bloodborne pathogens.

9. Who has responsibility to train contract workers?

The contractor has a continuing relationship with its workers, but the client employer often creates and controls the hazards. OSHA explains that the contractor employer would be expected to provide generic training. Client employers would normally provide site-specific bloodborne pathogens training. Together, the two would provide all the required training elements.

10. Are training records required to be kept?

Yes. Keep training records for at least three years after the training date. These records must include the date of training, the contents or a summary of the training session(s), the names and qualifications of the trainer(s), and the names and job titles of all trainees