Pumping up the pressure for effective bloodborne pathogen training
Is your organization becoming complacent in its bloodborne pathogen (BBP) training program? Over the last decade, training has continued to be the second most cited section of the standard. Ineffective training of the BBP program could cost organizations financially, but more importantly, it could be the culprit for injury to your employees.
Now is the time to pump up the pressure on an effective BBP training program. Let's explore the spectrum of good, better, and best training programs to ensure OSHA compliance, but most importantly worker safety.
What is good training?
A good training program complies with OSHA's minimum training requirements and must be completed at the initial job assignment and at least annually after that. The training must include:
- Explanation of regulations, epidemiology, and symptoms;
- Modes of transmission of bloodborne pathogens;
- Understanding of the employer's exposure control plan;
- Methods for recognizing tasks with potential exposure;
- Proper use of protective measures including PPE;
- Hepatitis B vaccine information and offering by employer;
- Emergency procedures;
- Reporting of exposure incidents;
- Process for post-exposure evaluation; and
- Interactive questions and answers with a subject matter expert.
This training can take various forms, including in-person presentations, videos, or e-learning. Regardless of the training type, having an expert on hand to answer questions and provide clarification is vital to meeting OSHA's minimum requirements.
How can I make my BBP training better?
Moving from good to better involves including additional hands-on elements into the training program, for example, setting up scenarios where designated workers must complete exercises related to the cleanup of a simulated blood spill. This hands-on format adds a memorable experience to the training. Also, organizations can tailor these scenarios to the specific workplace ensuring relevance and remembrance to the employees who participate.
What tools can I implement to have the best training?
The best bloodborne pathogen training goes beyond the good and the better. Best practices involve constant reinforcement training throughout the year. These types of training can include integrated toolbox talks, huddles, or pre-shift meetings. Typically, these activities last five to ten minutes each, and break down components of the full training plan or exercise into small, memorable segments. They can serve as quick refreshers on critical information necessary to effectively respond to an incident without drastically interrupting daily operations.
Who needs the training?
The requirements of the BBP standard (29 CFR 1910.1030) apply to all employers who have an employee(s) with occupational exposure (i.e., reasonably anticipated skin, eye, mucous membrane, or parenteral contact with blood or other potentially infectious materials (OPIM) that may result from the performance of the employee's duties).
It is important to note that even if an organization has only one employee who would meet this definition, the employer must include them in the BBP program and provide them with training.
What do I need to keep for training records?
Once you have your best program in place, keep in mind that OSHA has specific recordkeeping requirements under 1910.1030(h)(2)(ii). This requirement says that training records shall be maintained for 3 years from the date on which the training occurred and must include:
- Names and job titles of those trained,
- Dates of training,
- Contents of training sessions, and
- Names and qualifications of trainers.
Key to Remember: Effective bloodborne pathogen training must be more than the minimum required but incorporate a proactive approach that adds periodic refresher training sessions and hands-on exercises.
