Question 1

What are the qualifications that a person must possess to conduct employee training in bloodborne pathogens?

Accepted Answer

The person conducting the training is required to be knowledgeable in the subject matter covered by the elements in the training program, be familiar with how the course topics apply to the workplace that the training will address, and demonstrate expertise in occupational hazards of bloodborne pathogens. The trainer must also provide trainees an opportunity for interactive questions and answers with the trainer conducting the training session. See 29 CFR 1910.1030(g)(2)(vii)(N) and (g)(2)(viii) for trainer requirements. See §1910.1030(g)(2)(vii) for required training elements.

Question 2

What if an employee misses the annual retraining date for bloodborne pathogens?

Accepted Answer

If the annual training cannot be completed by the anniversary date, the employer should maintain a record indicating why the training is delayed and when the training will be provided. Retraining does not need to be performed on the exact anniversary date, but it must be provided on a date reasonably close to the anniversary date. Ideally, retraining is provided at least once every 12 months, within a period not exceeding 365 days.

Question 3

Does OSHA require our facility to mark aisles?

Accepted Answer

OSHA requires that the employer provide, and ensure each employee uses, a safe means of access and egress to and from walking-working surfaces, per 29 CFR 1910.22(c). OSHA explains that one way employers can meet this requirement is by “appropriately marking” passageways and permanent aisles as a means of identifying safe access and egress. In addition, according to §1910.176, where mechanical handling equipment is used, permanent aisles and passageways must be appropriately marked. Marking guidance can be found in two OSHA letters of interpretation dated May 15, 1972, and Feb. 14, 1977.

Question 4

Is computer- or online-based training acceptable for HAZWOPER training?

Accepted Answer

In OSHA’s view, computer- or online-based training, by itself, is not sufficient to meet the intent of the agency’s training requirements for HAZWOPER, 29 CFR 1910.120 for general industry or 29 CFR 1926.65 for construction. Therefore, computer or online training, in this case, must be supplemented by site-specific elements, hands-on training and exercises, and an opportunity for trainees to ask questions of a qualified trainer.

Question 5

Will a double-walled tank meet secondary containment requirements for oil spills?

Accepted Answer

Yes and no. Double-walled tanks are essentially a tank within another tank, equipped with an interstitial space and constructed in accordance with industry standards. The inner tank serves as the primary oil storage container while the outer tank serves as secondary containment. Double-walled tanks often satisfy the “general” and “specific” secondary containment provisions for bulk storage containers under EPA’s oil Spill Prevention, Control, and Countermeasure (SPCC) regulation at 40 CFR 112.

However, if there are openings below the liquid level of the container, the facility owner or operator may need to provide additional secondary containment to conform with industry standards and local codes. Also, the owner or operator may have to provide further secondary containment: (1) for transfers to and from the double-walled tank at loading and unloading areas, and (2) for piping that goes in and out of the double-walled tank. This is further explained in two EPA memos dated April 29, 1992, and August 9, 2002.

Tricia Hodkiewicz

ENVIRONMENTAL, HEALTH, AND SAFETY

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