Video training under the bloodborne pathogens standard

August 28, 1996

Jeffery A. Reynolds, CIH
Director, Industrial Hygiene
PMK Group
Consulting Engineers
[Recipient address omitted]
Dear Mr. Reynolds:

Thank you for your inquiry regarding the appropriateness of the usage of video presentations in meeting the Occupational Safety and Health Administration (OSHA) bloodborne training requirements.

29 CFR 1910.1030(g)(9)(2)(vii)(N) of the Bloodborne Pathogens Standard specifically requires that there be an opportunity for interactive questions and answers with the person conducting the training session.

Training the employee solely by means of a film or video without the opportunity for a discussion, constitutes a violation of the above referenced regulation. While video training programs are certainly appropriate for use as an aid in training, they must be supplemented with the required site specific information, and a person must be accessible for interaction.

Please bear in mind that many of the requirements of Bloodborne Pathogens Standard in particular are performance oriented. Compliance officers, therefore, will determine on a case-by-case basis, whether the training that has been provided is effective and adequate. This is accomplished through observations of work practices and employee interviews in an effort to determine that the training (including written material, oral presentations, film, videos, computer programs, or audiotapes) is presented in a manner that is appropriate to the employees' education, literacy level, and language.

We hope this information is responsive to your concerns. Thank you for your interest in worker safety and health.

Sincerely,
Ruth McCully, Director
Office of Health Compliance Assistance

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