A lot of factories and industrial workplaces have first aid teams and along with these dedicated response teams comes compliance with OSHA’s Blood borne pathogens (BPP) standard 1910.1030. Yet there is one small issue that many facilities overlook when it comes to their BBP training…
Almost all facilities contract out their first aid training to a 3rd party such as American Red Cross or American Heart Association. These are awesome training courses and I highly recommend either program; however, these programs recommend refresher training either every two years or three years and here lies the problem. 1910.1030(g)(2)(ii)(B) states:
1910.1030(g)(2)(ii) Training shall be provided as follows:
1910.1030(g)(2)(ii)(A) At the time of initial assignment to tasks where occupational exposure may take place;
1910.1030(g)(2)(ii)(B) At least annually thereafter.
This continues to be one of our most written findings in our audits. Facilities are doing their 1st aid training and including their BBP training with the first aid course and this is perfect; however, when they follow the first aid training refresher frequency of 2-3 years they almost always forget that the BBP training the first aid provider’s need is ANNUALLY. My recommendation is to do the first aid training annually rather than every 2-3 years. Unless you have EMT’s and nurses on your team, the skills they learn in the course are HOPEFULLY rarely used and thus they get rusty with them. So having the first aid training ANNUALLY is not that much $ and takes less than a day to complete.
Lastly, do NOT try and do this BBP training in-house, UNLESS there is an EMT/Nurse/Doctor available. The standard requires SPECIAL SKILLS to conduct this training.
1910.1030(g)(2)(viii) The person conducting the training shall be knowledgeable in the subject matter covered by the elements contained in the training program as it relates to the workplace that the training will address.
Also, if you are using CBT/On-Line/Video, etc. to provide this training, the students MUST HAVE ACCESS to a trained medical provider to get their questions, if any, answered. Here is what OSHA says about this matter:
Question 1: Does 1910.1030(g)(2)(viii) require that the person conducting bloodborne pathogens training be a health care professional?
Response 1: No. The Bloodborne Pathogens Standard, 29 CFR 1910.1030, does not specify a particular job classification for qualified trainers. 29 CFR 1910.1030(g)(2)(viii) does however require that the trainer be: knowledgeable in the subject matter covered by the elements contained in the training program. . . In OSHA’s bloodborne pathogens compliance directive (OSHA Instruction CPL 02-02-069), we state: [p]ossible 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 but not limited to, industrial hygienists, epidemiologists, or professional trainers, may conduct the training provided they are knowledgeable in the subject matter covered by the elements contained in the training program as it relates to the workplace. One way, but not the only way, knowledge can be demonstrated is the fact that the person received specialized training.
Question 2: Does this trainer need to physically be in the classroom or is it acceptable for the trainer to be contacted via phone, e-mail, etc. to answer any questions the students have during internet (electronic) training classes?
Response 2: The standard does not specify that the trainer be “physically” in the classroom while training is being conducted. The training requirements established under 29 CFR 1910.1030(g)(2)(vii)(N) require an employer to allow for an opportunity for interactive questions and answers with the person conducting the training session. Employers use a variety of methods to meet the intent of the standard. As an example, training conducted by compressed digital video (CDV) where the trainer is in one location but is in direct communication with the trainees would provide for an interactive exchange and is an acceptable method for meeting the requirements of the standard. Additionally, OSHA has previously stated that an employer can meet OSHA’s requirement for trainees to have direct access to a qualified trainer by providing a telephone hotline. The trainer must be accessible to employees during the time of training. It is important to note, too, that employees must be trained initially prior to being placed in positions where occupational exposure to blood or other potentially infectious materials (OPIM) may occur.
During a phone conversation with one of our staff members, you clarified that at your workplace, there may be circumstances where an employee is completing the electronic training session at a time when the designated trainer is not readily accessible and the protocol is for the employee to leave a phone message and wait for a response. You mentioned that staff members working on evening shifts or weekends when the healthcare professional or designated trainer is not on duty would therefore not have the opportunity for interactive discussion with the trainer during the training session. This training scenario would not meet the intent of the standard and would constitute a violation of 1910.1030(g)(2)(vii)(N). Employees must have direct access to a qualified trainer at the time the training is being conducted. For your information, we have enclosed two previously written letters of interpretation where OSHA addressed questions similar to those raised in your inquiry. [Please see letters to Mr. John Mateus, dated June 26, 2003 and; Ms. Nancy Wicklin, RN, MS, dated January 15, 1999.]
Hope this helps shore up your BBP complaince.