If OSHA showed up at your office today, do you have documentation AND could every member of your staff (including yourself and new employees) answer yes to the following questions:
- Have you receive Bloodborne Pathogens training within the past twelve months?
- Could you ask the trainer questions about things you could not understand?
- Did the training include items specific to your practice?
- How do you manage a needlestick?
- How does your staff define regulated waste?
- Where do you meet in the event of a fire?
- How would you manage a patient who presented with H1N1 or other communicable diseases?
If you answered no to any of these questions you would fail to meet the most basic requirements set forth under 29 CFR and would be subject to citations and fines per individual training deficiency identified.
The first question most OSHA Enforcement Officers will ask your staff during an interview is: “Have you had training?” This training could be referring to anything from Bloodborne Pathogens to HAZCOM to Personal Protective Equipment, the list could go on. No matter the size or type of practice training is a key element to obtain complete compliance. OSHA requires that all safety training provided be specific to the hazards identified in your office.
Who needs OSHA training?
- Full Time Employees
- Part Time Employees
- Seasonal Employees
- Temporary Employees
- Subcontracted Employees (e.g., RDH, Anesthesiologists, Lab Techs, Rad Techs)
- Per-Diem Employees
- Working Interviews
- Family Member Workers
- Volunteers (under certain circumstances)
When is training required?
- At the time of initial assignment
- When job duties change
- At least annually thereafter
- Annual training for all employees shall be provided within one year of their previous training
- Additional requirements may apply
I train my staff using a video, does this count?
- No. The OSHA Enforcement Policy (CPL 02.02.069) states:
“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.
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.
Training the employees solely by means of a film or video without the opportunity for a discussion period would constitute a violation of this paragraph.”
I don’t train my new employees until our annual update, is this ok?
- No. OSHA regulations state “employees must be trained initially prior to being placed in positions where occupational exposure may occur”.
I hired a new employee and they received training at their previous place of employment, do I still have to train them?
- Yes, even though the employee’s previous employment may have been similar, the training provided them must be site specific and cover items unique to your facility.
Here at Compliance Alliance, all courses are conducted on site, in an engaging and interactive format with one of our highly trained and experienced Registered Nurses or Safety Engineers.
Onsite training eliminates the lost production, increased cost of non-productive work hours, and liability of workers traveling off site for education.