Bloodborne pathogens training: Your top 3 questions answered

Bloodborne pathogens (BBP) training equips employees with the knowledge and skills to protect themselves from potential exposure to bloodborne diseases such as HIV, hepatitis B, and hepatitis C. Following are the top three questions employers have about training.

1. Who needs BBP training and how often must it be provided?

Employees with occupational exposure to BBP must be trained. Occupational exposure is defined as “reasonably anticipated skin, eye, mucous membrane, or parenteral contact with blood or OPIM [other potentially infectious materials] that may result from the performance of an employee’s duties.” Employees in many occupations, including first responders, housekeeping personnel, security guards, and healthcare employees, may have occupational exposure.

Employees must be trained prior to initial exposure and at least annually after that. Annual training must be provided within one year of employees’ previous training. Additional training must be given when changes such as modification of tasks or procedures or institution of new tasks or procedures affect the employee’s occupational exposure. The additional training may be limited to addressing the new exposures created.

2. Will a BBP training video on its own satisfy OSHA’s requirements?

No, employers must provide workplace-specific information as well as an opportunity for employees to ask questions. In CPL 02-02-069, OSHA says, “A generic computer program, even an interactive one, is not considered appropriate unless the employer supplements such training with the site-specific information required (e.g., the location of the exposure control plan and the procedures to be followed if an exposure incident occurs) and a person is accessible for interaction. Trainees must have direct access to a qualified trainer during training. OSHA’s requirement can be met if trainees have direct access to a trainer by way of a telephone hot line. The use of an electronic mail system to answer employee questions is not considered direct access to a qualified trainer, unless the trainer is available to answer e-mailed questions at the time the questions arise.”

3. Must training be conducted by a healthcare professional?

Not necessarily. OSHA requires that the person conducting the training be knowledgeable in the subject matter covered by the elements contained in the BBP training program as it relates to the workplace that the training will address.

Possible trainers include a variety of healthcare professionals such as infection control practitioners, nurse practitioners, registered nurses, occupational health professionals, physician’s assistants, and emergency medical technicians. Non-healthcare professionals, such as industrial hygienists, epidemiologists, or professional trainers, may conduct the training provided they’re knowledgeable in the subject matter covered by the elements contained in the training program as it relates to the workplace.

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 by 1910.1030(g)(2)(vii)(A) through (N).

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