OSHA Bloodborne Pathogens Training Requirements for Care Providers

If anyone on your team could reasonably come into contact with blood or other potentially infectious materials on the job, federal OSHA rules require bloodborne pathogens training before that work starts and again every year. For I/DD, adult day, assisted living and home care providers, that usually means a large share of direct care staff. This guide walks through what the standard actually requires, what the training has to cover, how online courses fit in, and which records you need to keep.

Who the standard covers

OSHA's Bloodborne Pathogens Standard, 29 CFR 1910.1030, applies to all occupational exposure to blood or other potentially infectious materials (OPIM). The rule defines occupational exposure as "reasonably anticipated skin, eye, mucous membrane, or parenteral contact" with blood or OPIM that may result from an employee's duties.

The rule doesn't list job titles. Instead, each employer with exposed staff has to prepare a written exposure determination that lists:

• job classifications in which all employees have occupational exposure
• job classifications in which some employees have occupational exposure
• the tasks and procedures that cause exposure for those "some employees" job classes

That determination has to be made without regard to personal protective equipment. In other words, the fact that a DSP wears gloves doesn't take the job out of the standard. When you review your job descriptions, ask whether staff give first aid, help with personal care, handle sharps such as lancets or insulin pens, or clean up after an injury, and record the answer by job class.

Federal vs. state coverage. Federal OSHA covers most private-sector employers. According to OSHA's State Plans page, 22 OSHA-approved State Plans cover both private-sector and state and local government workers, and seven more cover only state and local government workers. State Plans must be at least as effective as federal OSHA, and some add their own rules. Washington is one example: its DDA residential training rule points to the state's own bloodborne pathogens rule and requires the training every year (see our Washington DSP training requirements guide). If you operate in a State Plan state, check its version of the rule too.

When training is required

Under 29 CFR 1910.1030(g)(2), employers must train each employee with occupational exposure:

• at the time of initial assignment to tasks where occupational exposure may take place
• at least annually after that, and annual training must be provided within one year of the previous training
• again when tasks or procedures change in a way that affects the employee's exposure (this extra training can be limited to the new exposures)

OSHA has stressed in its interpretation letters that employees must be trained before they are placed in positions where exposure may occur. Training must be provided at no cost to the employee and during working hours, and the materials have to fit the employee's educational level, literacy and language.

"Annually" means a rolling one-year clock from each person's last session, not a calendar-year deadline. That's easy to miss when hire dates are spread across the year.

What the training must cover

The standard lists 14 minimum elements in paragraph (g)(2)(vii). Training must include:

1. An accessible copy of the regulatory text of the standard and an explanation of its contents
2. A general explanation of the epidemiology and symptoms of bloodborne diseases
3. An explanation of how bloodborne pathogens are transmitted
4. An explanation of your exposure control plan and how the employee can get a copy of it
5. How to recognize tasks and activities that may involve exposure
6. The use and limits of engineering controls, work practices and personal protective equipment (PPE)
7. The types, proper use, location, removal, handling, decontamination and disposal of PPE
8. The basis for selecting PPE
9. Information on the hepatitis B vaccine, including its efficacy, safety, method of administration and benefits, and that it is offered free of charge
10. What to do and whom to contact in an emergency involving blood or OPIM
11. The procedure to follow after an exposure incident, including how to report it and the medical follow-up that will be available
12. The post-exposure evaluation and follow-up the employer must provide
13. The signs, labels and color coding required by the standard
14. An opportunity for interactive questions and answers with the person conducting the training

The person conducting the training must be knowledgeable in the subject matter "as it relates to the workplace that the training will address," under paragraph (g)(2)(viii). OSHA has said that person doesn't have to be a healthcare professional, but they do have to know the content and your workplace.

Can online training meet the requirement?

Yes, with two conditions. OSHA's enforcement directive (CPL 02-02-069, section XIII.G.8), as quoted in a 2016 OSHA interpretation letter, says a generic computer program, even an interactive one, isn't appropriate on its own unless the employer:

• adds the site-specific information, such as where the exposure control plan is kept and what to do if an exposure incident happens, and
• makes a qualified trainer accessible for questions during the training

OSHA has said a telephone hotline to a qualified trainer can satisfy the question-and-answer requirement. Email doesn't count unless the trainer answers at the time the questions come up. In a 2003 letter, OSHA added that a qualified trainer must be available even if no one ends up asking a question. In a 2008 letter, it said leaving a voicemail for a trainer who isn't on duty, as can happen on evening or weekend shifts, does not meet the standard.

A practical setup for agencies that train online:

• Use an online course for the general content (transmission, PPE, hepatitis B vaccine, labels and so on).
• Add a short, agency-specific segment or handout covering your exposure control plan, where the plan and PPE are kept, and your exposure-incident reporting steps.
• Name a knowledgeable staff member, such as a nurse or trained supervisor, who can be reached by phone or in person while staff are training, and schedule training for times when that person is available.
• Record who that trainer was, since the training record has to include it.

Related requirements that go with training

Training is one part of the standard. A few other pieces connect directly to it.

Exposure control plan. Employers with exposed staff need a written exposure control plan. A copy must be accessible to employees, and the plan must be reviewed and updated at least annually, and whenever new or changed tasks, procedures or positions affect exposure.

Hepatitis B vaccination. The vaccine series must be made available at no cost to every employee with occupational exposure, after they've received the training on the vaccine and within 10 working days of initial assignment. That doesn't apply if the employee has already had the full series, antibody testing shows immunity, or the vaccine is medically contraindicated. Employees who decline must sign the declination statement in Appendix A of the standard, and they can change their minds later and still get the vaccine.

Post-exposure follow-up. After an exposure incident, employers must make post-exposure evaluation and follow-up available at no cost to the employee. Training item 11 above is where staff learn how to report an incident and what follow-up to expect.

Records to keep

Paragraph (h)(2) sets what a bloodborne pathogens training record must include:

• the dates of the training sessions
• the contents or a summary of the training sessions
• the names and qualifications of the people conducting the training
• the names and job titles of everyone who attended

Training records must be kept for 3 years from the date of the training. They must be provided on request to employees, employee representatives and OSHA.

Medical records are separate. Each exposed employee's record, including hepatitis B vaccination status and dates, has to be kept confidential and retained for the duration of employment plus 30 years, under 29 CFR 1910.1030(h)(1). Don't store vaccination records in the same open training file that supervisors use.

A quick self-check for each exposed employee's training file:

For more on keeping these dates straight across a whole staff, see our guide to tracking employee training in a care agency.

How TES helps

Our catalog includes a 1-hour Bloodborne Pathogens (BBP) course for care workers, along with Infection Control: Universal Precautions and Basic Safety, which covers how infections spread, protective equipment and what to do after an exposure. Both can cover the general content of your annual training. You'll still need to add your agency's site-specific information and make a knowledgeable trainer available for questions, as described above.

Training & eTracking Solutions has trained more than 200,000 professionals since 2010, and our catalog includes 400+ courses and programs. As an NADSP Accredited Education provider, our courses count toward the DSP-I and DSP-II credentials. Contact us to set up annual bloodborne pathogens training and tracking for your team.

This article summarizes federal OSHA's Bloodborne Pathogens Standard, 29 CFR 1910.1030, as published in the Electronic Code of Federal Regulations, and OSHA interpretation letters. It is not legal advice. OSHA-approved State Plans, state licensing rules and Medicaid waiver requirements may add to these rules, so check the current text before making compliance decisions.