Bloodborne pathogens: When to train and who can deliver

The bloodborne pathogen standard isn't just for healthcare employers; potentially every employer has covered workers. Every employer should determine which employees (if any) are covered, when they need training, and who is qualified to deliver that training.

Training must be provided to employees who have "occupational exposure." Essentially, this means the employee's assigned job duties could result in contact with blood or other potentially infectious materials (OPIM). For example, employees who are designated by the employer are first aid responders would be covered by the standard. 

This doesn't mean every employee who takes a first aid course is covered. The worker must actually be assigned or designated as a responder. Individuals who choose to respond as Good Samaritans (but are not designated responders) are not covered.

When to train

Covered employees must receive initial training at the time they are assigned job duties that may involve exposure (e.g., when they have "occupational exposure"). The regulation at 1910.1030(g)(2)(vii) lists more than a dozen topics that must be addressed. There is no specified time or number of hours that must be spent in training, but all listed items must be covered.

Covered employees must also receive training annually thereafter, and may need "additional training" as needed. According to OSHA, the annual training need not cover all the topics from the initial training. A letter of interpretation from August 31, 1997, says "the annual training can consist of only a quick review of previous training material." Of course, any changes or new information should be covered as well. 

The letter also clarifies that "additional training" be provided when changes to tasks or procedures affect the employee's exposure, or when new tasks or procedures are implemented. Basically, employers should not wait until the next annual training to inform employees of procedural changes. However, this "additional training" may be limited to covering the new information or change in policy; it does not have to cover all topics from the initial training.

Who can train

The person who delivers the training need not be a health care professional, but the regulation specifies that the trainer "be knowledgeable in the subject matter" to be covered, and how it relates to the workplace.

Another letter of interpretation from January 17, 2008, says that non-healthcare professionals may conduct the training if they are "knowledgeable in the subject matter." One possible way to demonstrate that the trainer has such knowledge would be to show that "the person received specialized training." This suggests that the expectations for being "knowledgeable" means something more than being self-taught.