Ask the expert—Qualifications as bloodborne pathogens trainer
Q: When we do our initial and annual bloodborne pathogens training, does the presenter have to be one of our physicians?
A: No, a physician does not have to oversee bloodborne pathogens training.
Enforcement Procedures for the Occupational Exposure to Bloodborne Pathogens explains the trainer requirements under paragraph (g)(2)(viii) of the bloodborne pathogens standard. The trainer or presenter must be knowledgeable in the subject matter of the training program as it relates to the workplace that the training will address.
Trainers could be, but are not limited to such healthcare professionals as: infection control practitioners, nurse practitioners, registered nurses, occupational health professionals, physician’s assistants, and emergency medical technicians, according to the Enforcement Procedures.
“In some workplaces, such as dental or physicians’ offices, the individual employer may conduct the training, provided he or she is familiar with bloodborne pathogen exposure control and the subject matter required.” the document states.
HCPro’s OSHA Training Program for Healthcare and Basic Medical OSHA Compliance Manual Kit makes it easy to administer a program and train staff for OSHA bloodborne pathogens compliance.
Downloads with information on annual and initial training are available on the Tools page.
So, what do you do in your facility for bloodborne pathogens training: bring in outside expertise; have a dedicated trainer position; staff member doubles as OSHA trainers?
Did you find this advice helpful? Learn how you can get all your OSHA questions answered by registering for OSHA Healthcare Advisor’s “Q&A Roundtable: Solutions to Your Compliance Challenges” audioconference.
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David LaHoda
David LaHoda, the managing editor of Medical Environment Update and OSHA Watch, has produced healthcare training videos and consulted for medical practices and ambulatory healthcare facilities.
David has written 196 posts.
Comments
Are computer based learning modules acceptable to provide the Bloodborne Pathogen training? I always thought that this should be done real time by the person designated in the organization in order to meet the required “available to ask questions” portion of the program.
You are correct, whatever training process you use for bloodborne pathogens, you must account for interactive Q&A requirement. OSHA says you can meet this interactive requirement by having the trainer on site (obviously) or providing a telephone hot line.
As for email and paging provisions, OSHA says those methods do not qualify as direct access, unless the trainer is available to answer at the time the questions arise. Responding within the hour or shortly after the training concludes is not compliant.
Could the trainer be a human resources staff person, as long as the training material is reviewed by an MD, RN, or other healthcare provider?
Yes, as long as the trainer meets the qualifications as stated in the standard, 1910.1030(g)(2)(viii):
“The person conducting the training shall be knowledgeable in the subject matter covered by the elements contained in the training program as it relates to the workplace that the training will address.”
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