- Bloodborne pathogens training for contract and temporary employees is a shared responsibility between the contractor/staffing agency and the client/host employer.
- Generally, the contractor/agency handles generic bloodborne pathogen information and training, and the client/host employer handles site-specific bloodborne pathogen information and training.
In contract situations, both the contractor and client employer share responsibility for ensuring that contract employees are protected. Likewise, for temporary employees, the staffing agency and host employer are considered joint employers. In either scenario, it is in the interest of both employers to ensure that required training has been provided:
- Contract employees: The contractor maintains a continuing relationship with its employees, but the client employer often creates and controls the hazards. The Occupational Safety and Health Administration (OSHA) explains that the contractor employer is expected to provide generic training in universal precautions, the concept of treating all human blood and other potentially infectious materials (OPIM) as if known to be infectious. Client employers, on the other hand, normally provide site-specific bloodborne pathogens training.
- Temporary employees: As joint employers, both the staffing agency and the host employer are responsible for ensuring that the temporary employee is properly trained. However, the two may decide that a division of the training responsibility may be appropriate. Generally, the staffing agency is responsible for providing generic bloodborne pathogen information and training, while the host employer is typically responsible for providing site-specific bloodborne pathogens training.