• Bloodborne pathogens training must be made available by employers during paid work hours at no cost to the employees.
• Training must take into account employees’ comprehension and be provided in languages, education levels, and formats that they can understand.
• Training can be provided in a variety of formats, as long as it includes real-time trainer interaction, site-specific information, and hands-on practice.

It’s the employer’s responsibility to institute a bloodborne pathogens training program and ensure employee participation.

Bloodborne pathogen information and training must be provided during paid working hours, at no cost to the employee. Other considerations in how to train involve trainee comprehension, training format, opportunities for questions, and hands-on training.

Comprehension

Training content and vocabulary must be appropriate for trainees’ education level, literacy, and language. In practical terms, instruction needs to be provided using both a language and vocabulary trainees can understand. If a trainee does not speak or comprehend English, instruction must be provided in a language the trainee can understand. Moreover, if the trainee’s vocabulary is limited, the training must account for that limitation. If a trainee is illiterate, then instruction should be available that requires no reading; telling the trainee to read training materials doesn’t satisfy the training obligation.

Format

The Occupational Safety and Health Administration (OSHA) doesn’t restrict the training format that employers use. Audiovisuals, classroom instruction, interactive video, and online and computer-based training are all good tools that can be used as part of an effective training program. Using a variety of audio, visual, and online tools may allow the training to fit with different learning styles and levels of experience among trainees.

However, acceptable training requires interaction and site-specific information. Training the employees solely by means of a film or video without the opportunity for a discussion would constitute a violation. Similarly, a generic online or computer program, even an interactive one, is not sufficient, unless the employer:

• Supplements this training with the site-specific information required (e.g., the location of the exposure control plan and the procedures to be followed if an exposure incident occurs); and
• A trainer is available for interaction.

Opportunities for questions

During training, it is critical that trainees have the opportunity to ask questions and receive answers where material is unfamiliar to them. Frequently, a trainee may be unable to go further with the training or to understand related training content until a response is received. Therefore, under the standard, trainees must have direct access to a qualified trainer during training. However, the trainer does not need to be in the room with the trainee. OSHA’s requirement may be met if trainees have direct access to a trainer by way of a telephone hotline. Email is not considered direct access, unless the trainer is available to answer emailed questions as soon as they arise.

Hands-on training

Sufficient hands-on training is important because it allows trainees to interact with equipment and tools in the presence of a qualified trainer and to learn or refresh their skills through experience. It gives the trainer a chance to assess whether the trainees have mastered the proper techniques.

Must-read OSHA interpretations

While OSHA offers many letters of interpretation on 1910.1030, two letters are especially helpful for an employer looking to comply with the bloodborne pathogens training requirements:

• Appropriateness of computer-based interactive training programs to satisfy required OSHA training, OSHA letter of interpretation, 6/11/1997
• Appropriateness of the usage of video presentations in meeting the OSHA bloodborne training requirements, OSHA letter of interpretation, 8/28/1996