Requirement guide · US federal
OSHA bloodborne pathogens training requirements
Who needs it, what it must cover, how often, and whether online training counts. Based on 29 CFR 1910.1030(g)(2) and OSHA's own interpretations.
The short answer
- Who
- Every employee with occupational exposure to blood or other potentially infectious materials
- When
- At initial assignment, then at least every 12 months, and again when tasks or procedures change
- What
- 14 required elements, listed in (g)(2)(vii)(A) to (N)
- How
- Free to employees, during working hours, in language they understand, with live Q&A with a qualified trainer
- Records
- Keep for 3 years
Who needs the training
The standard applies to any employee who could "reasonably anticipate" contact with blood or other potentially infectious materials (OPIM) as part of their job. It's not limited to hospitals. Common examples outside healthcare include designated first-aiders, janitorial and housekeeping staff, school nurses, tattoo and body art studios, law enforcement and some hospitality roles.
Your exposure control plan should list which job classifications have exposure. That list decides who gets trained.
What the training must cover
Paragraph (g)(2)(vii) lists 14 elements. In plain English, training must cover:
- Access to a copy of the standard, with an explanation
- Bloodborne diseases: epidemiology and symptoms
- How they're transmitted
- Your exposure control plan, and how to get a copy
- How to recognise tasks that may involve exposure
- Ways to prevent or reduce exposure, and their limits
- PPE: types, use, location, removal, handling, decontamination and disposal
- How PPE is selected
- The hepatitis B vaccine, including that it's free
- What to do and whom to contact in an emergency involving blood
- What to do after an exposure incident, including reporting and medical follow-up
- The post-exposure evaluation and follow-up the employer must provide
- Signs, labels and colour coding
- An opportunity for interactive questions and answers with the person conducting the training
Can it be done online?
Yes, but not on its own. OSHA's interpretation letters say computer-based training can be part of a program, but learners must have direct access to a qualified trainer at the time of training. A phone line answered during the course works. A live session works. An email inbox answered the next day does not: OSHA has said a 16-hour delay means the employee wasn't properly trained.
OSHA also warns against relying only on generic, packaged programs, because the training must include details specific to your workplace.
Who can deliver it
The trainer must be knowledgeable in the subject matter as it relates to your workplace. There's no OSHA trainer certification for bloodborne pathogens, but the person should know your exposure control plan and your procedures.
What records to keep
Keep training records for three years from the training date. Each record needs the dates, a summary of the content, the names and qualifications of the trainers, and the names and job titles of everyone trained.