August 31, 1997

Dr. Howard Mertz, Assistant Professor of Medicine
Vanderbilt University Medical Center
1414 The Vanderbilt Clinic
Nashville, TN 37232-5280

Dear Dr. Mertz:

This is in response to your letter dated June 19, 1997, where you expressed a concern about the Occupational Safety and Health Administration's (OSHA) requirement for training. Specifically[,] your letter referenced the annual training required by the Occupational Exposure to Bloodborne Pathogen standard, 29 CFR 1910.1030.

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 potentially 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 newest information or change in procedure or policy, and does not have to cover all the topics included in the initial training. 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 letter states that you are well informed on the mandated subjects such as the risks of bloodborne diseases and you believe annual training is excessive. If all the participa[nts] have already been through the initial training, the annual training can consist of only a quick review of previous training material. The more important function of annual training is to inform employees about new and emerging healthcare worker issues and what policies the employer has in place to address them. For example, OSHA requires the employer to follow the U.S. Public Health Service recommendations, when medically indicated, for post-exposure prophylaxis. These recommendations are not fixed, but rather are expected to change as more is learned about the treatment for bloodborne pathogens. The training time will be well spent if the employees can save precious time following an exposure incident by knowing what arrangements for treatment the employer has provided for them in the Exposure Control Plan.

In your letter you inquired about the process for the development of this OSHA standard. The development of this standard by OSHA took more than five years, beginning with close cooperation on the development of a proposed standard with the Centers for Disease Control and Prevention (CDC), Department of Health and Human Services. The proposed standard was based on the scientifically sound infection control practice of "universal precautions" originally established by the CDC for handling of body fluids known to transmit HIV.

Following the publication of the proposed standard the public, particularly the dental and medical communities, submitted approximately 3,000 comments to the official record. In addition, OSHA held five public hearings, in Washington, D.C., Chicago, New York City, Miami and San Francisco, where 440 individuals and organizations testified. The comments and testimony underwent extensive review and analysis, and many of the suggested changes were adopted in the final rule. In addition, the U.S. Congress held a series of hearings concerning the proposed Bloodborne Pathogens standard. Many individuals and groups testified at these hearings, including the American Medical Association and the American Dental Association.

We hope you find this information useful. Thank you for your interest in safety and health. If you have further questions, please call Wanda Bissell of my staff at (202) 219-8036 ext. 49.

Sincerely,

Stephen Mallinger, Acting Director
Office of Health Compliance Assistance