Annual bloodborne pathogen training frequency

February 2, 1993

The Honorable Steve Gunderson
U.S. House of Representatives
[Recipient address omitted]
Dear Congressman Gunderson:

This is in response to your letter of December 22, 1992 to Mr. Frederich Drayton in which you requested a clarification of the Occupational Safety and Health Administration (OSHA) regulation 29 CFR 1910.1030, "Occupational Exposure to Bloodborne Pathogens." Your letter was referred to us for response.

Specifically, you wrote regarding the concerns of a constituent, Mrs. Lois Siefert, that "OSHA regulations now state that the Red Cross volunteers must have 5 hours of training every 90 days." This statement is incorrect. OSHA's requirements regarding the content and frequency of training are limited to paragraph (g)(2) of the standard.

Section (g)(2)(ii) specifies that training shall be provided at the time of initial assignment to tasks where occupational exposure to blood or other potential infectious materials (OPIM) may take place and at least annually thereafter. Section (g)(2)(v) states that additional training shall be provided when changes such as modification of tasks or procedures, or institution of new tasks or procedures affect the employee's occupational exposure. In this case, the additional training may be limited to addressing the new exposures created.

While the length of training is not specified, section (g)(2)(vii) lists the elements that must be included in the training program, including explanations of symptoms and modes of transmission of bloodborne diseases, location and handling of personal protective equipment, information on the hepatitis B vaccine, and follow-up procedures to be taken in the event of an exposure incident. Your constituent should bear in mind, that the training requirements of this standard are performance oriented. Compliance officers will determine, on a case-by-case basis, whether the training that has been provided is effective and adequate.

We hope this information is responsive to your concerns. If your constituent has any further questions, she may contact OSHA's regional bloodborne pathogens coordinator in Chicago, Illinois at (312) 353-2220.

Sincerely,
Roger Clark,
Director
Directorate of Compliance Programs

[Requester letter reproduced on OSHA page; omitted here.]