Bloodborne pathogen training for employees
The bloodborne pathogen (BBP) 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.
Employers must provide training 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 the employer designates as first-aid responders would need BBP training.
This doesn’t mean every employee who takes a first-aid course is covered. The worker must be assigned or designated as a responder. Individuals who choose to respond as Good Samaritans (but are not designated responders) are not covered.
At a minimum, your BBP program must:
- Identify who to train,
- Designate trainers,
- Discuss training retention, and
- Provide job-focused training.
When to train for bloodborne pathogens
Covered employees must receive initial training when 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 to address. There isn’t a minimum number of training hours defined in the standard, but all listed items must be covered so workers understand them adequately to perform their job safely.
Covered employees must also receive training annually after that 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, states, “the annual training can consist of only a quick review of previous training material.” Trainers should cover changes and new information as well.
In the letter, OSHA clarifies that “additional training” must be provided when changes to tasks or procedures affect the employee’s exposure or while implementing new tasks or procedures. However, this “additional training” may be limited to covering the latest information or change in policy; it does not need to cover all topics from the initial training. Employers should not wait until the next annual training to inform employees of procedural changes.
Who can trainfor bloodborne pathogens
The person who delivers the training need not be a health care professional. Still, 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, states 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” mean something more than being self-taught.
Revisit the BBP training after a month, checking on trainees to determine if they remembered and implemented what they learned. Trainees might even have questions based on their attempts to apply the new knowledge. If they weren’t sure how to use it or incorporate the new information, they aren’t getting the benefits. Also, if you’re delivering information in several short sessions, each meeting allows you to review the material covered in the previous session and answer any questions.
Personalize BBP Training
Personalizing training doesn’t mean tailoring the material to each individual but explaining how the information relates to them. The more trainees can relate to BBP and see how it impacts them personally, the more they’ll understand it and recognize its value.
If they cannot see how the training applies to their jobs or how to use the information, they’re less likely to follow it. I’d provide different training for my workers who perform cleaning duties than other workers who may only discover a BBP hazard. If workers might only find a BBP hazard, they may need to know more about reporting it correctly and not about cleanup.
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