Safety & Loss Prevention
OSHA's bloodborne pathogen training FAQ's
Excerpts from “02/01/1993 – Most frequently asked questions concerning the bloodborne pathogens standard.”
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Q70. Which employees must be trained?
A70. All employees with occupational exposure must receive initial and annual training.
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Q71. Should part-time and temporary employees be trained?
A71. Part-time and temporary employees are covered and are also to be trained on company time.
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Q72. Who has the responsibility for training workers employed by agencies which provide personnel (e.g., nurses) to other employers?
A72. As stated in a similar answer [in Question 5], OSHA considers personnel providers, who send their own employees to work at other facilities, to be employers whose employees may be exposed to hazards. Since personnel providers maintain a continuing relationship with their employees, but another employer (your client) creates and controls the hazard, there is a shared responsibility for assuring that your employees are protected from workplace hazards. The client employer has the primary responsibility for such protection, but the "lessor employer" likewise has a responsibility under the Occupational Safety and Health Act.
In the context of OSHA's standard on Bloodborne Pathogens, the personnel provider would be required to provide the general training outlined in the standard., the client employer would be responsible for providing site-specific training.
The contract between the personnel provider and the client should clearly describe the training responsibilities of both parties in order to ensure that all training requirements of the standard are met.
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Q73. What are the qualifications that a person must possess in order to conduct employee training regarding bloodborne pathogens?
A73. The person conducting the training is required to be knowledgeable in the subject matter covered by the elements in the training program and be familiar with how the course topics apply to the workplace that the training will address. The trainer must demonstrate expertise in the area of occupational hazards of bloodborne pathogens.
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Q74. Where could information be obtained for conducting training on the Bloodborne Pathogens Standard?
A74. OSHA's Office of Information and Consumer Affairs (OICA) has developed brochures, factsheets, and a videotape on the standard. Single copies of the brochure and factsheets can be obtained by writing OSHA Publications, 200 Constitution Avenue, NW, Room N3101, Washington, DC 20210 or by calling (202) 219-8148 the videotape is available through the National Audio Visual Center, and the number is (301) 763-1896. All information available through OICA should be used as a supplement to the employer's training program. Other sources of information include local Area and Regional OSHA Offices. In addition, each Regional Office has a Bloodborne Pathogens Coordinator who answers compliance and related questions on the standard.
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Q75. Who are some examples of persons who could conduct training on the bloodborne standard?
A75. Examples of health care professionals include infection control practitioners, nurse practitioners, and registered nurses. Non-health care professionals include industrial hygienists, epidemiologists or professional trainers, provided that they can demonstrate evidence of specialized training in the area of bloodborne pathogens.
Last updated 03/16/2010
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