All potentially exposed healthcare workers are required to have training in bloodborne pathogens “at the time of initial assignment to tasks where occupational exposure may take place” and “at least annually thereafter.” Unlike other types of training, OSHA has not released any new guidance on this issue. This means the rules are still in effect.

“At the time of initial assignment to tasks” 

All new workers who could potentially be exposed MUST have training in the hazards BEFORE they start performing those tasks. This applies to any industry and any hazard. OSHA will be unlikely to ignore a violation of this kind and has historically given its highest fines in this area.

To meet this need, TMC offers on-line training for new employees. This is available in our full-service plan for free as part of your service. We also have eCompliance packages that include online training or you can purchase just the online training by itself for a very reasonable cost.

“At least annually” 

OSHA requires that employee training be conducted at least annually, by which they mean that employees must be provided re-training within a time period not exceeding 365 days. This annual training need not be performed on the exact anniversary date of the preceding training but should be reasonably close to the anniversary date.

If the annual training cannot be completed by the anniversary date, the employer should maintain a record indicating why the training has been delayed and when the training will be provided. A letter from the organizer of a group training/convention with the new date or the confirmation from TMC for a scheduled training can be used to meet this requirement.

“Employees are trained to protect themselves from…new hazards.”

Keep in mind that the term “at least annually” is generally regarded as indicating that circumstances that warrant more frequent training may occur. It is extremely important that employees are trained to protect themselves from all known workplace hazards, including new hazards that may result from changes. The pandemic definitely constitutes a new hazard in OSHA’s eyes.

TMC has been providing training for everyone in healthcare on the new pandemic hazard since its onset with the following:

  • Inclusion within your on-site training
  • Free live webinars
  • Free recorded webinars on our website
  • Free written pandemic plan

(Virginia practices be aware that the new state-specific training will be available as an on-line module soon. TMC will be offering a written plan and employee training in time to meet the new regulations.) Keep informed and keep safe.