Training Under OSHA’s Bloodborne Pathogens Standard

The Occupational Safety and Health Administration says you have to train all employees with occupational exposure to blood or other potentially infectious materials. Here is clarification about how that regulation translates into practice in a medical office.

Trainer Qualifications  

The trainer does not have to be a health care professional but must be someone who is "knowledgeable in the subject matter covered by the elements contained in the training program," for example, an industrial hygienist, epidemiologist, or professional instructor with specialized training.  

Trainer Accessibility

The trainer does not have to be physically in the classroom while training is under way, but interactive questions and answers with the instructor must be possible during the training session. A variety of methods will meet this standard. Examples are a live Webinar with direct phone communication between trainer and trainees, independent Web-based modules with direct access to a qualified trainer through an Internet live chat session, or a workbook with direct access to the trainer via telephone hotline.  

An arrangement whereby a student has to leave a message (e.g., e-mail or voice mail) with a trainer and wait for a response does not meet the OSHA training standard.  


You must train your employees initially prior to placing them in positions where occupational exposure to blood or other potentially infectious materials may occur, and annually thereafter.  

Also, when some change occurs in your office or in the regulations that might affect your employees' exposure, you must provide special training regarding the new exposure.   


TMA Practice E-tips main page

Last Updated On

October 07, 2022

Originally Published On

March 23, 2010

Related Content

Human Resources | OSHA