April 15, 1992

Mr. James R. Cross
Attorney at Law
Infection Control/Emerging Concepts Inc.
Post Office Box 2565
Springfield, Virginia 22152

Dear Mr. Cross:

This is in response to your letter of January 23, in which you requested clarification concerning the training requirements of 29 CFR 1910.1030, "Occupational Exposure to Bloodborne Pathogens." We apologize for the delay in this response.

Specifically you asked how the training required under this standard should be presented to satisfy the requirements and to protect employers against possible citations and penalties. While the Occupational Safety and Health Administration (0SHA) compliance officers will include an evaluation of the training program in their inspections, it is the responsibility of the employer to verify the competency of the trainers based on the completion of specialized courses, degree programs, or work experience. While the trainer must be familiar with the manner in which the elements in the training program relate to the particular workplace, the standard does not prescribe a specific length of time that would constitute experience. The trainer must be able to address such site-specific issues as the location of the exposure control plan and the procedures to be followed if an exposure incident occurs.

Possible trainers include a variety of health care professionals such as infection control practitioners, nurse practitioners, registered nurses, or physician's assistants. Non-health care professionals such as industrial hygienists, epidemiologists, or professional trainers may also be considered competent if they can demonstrate evidence of specialized training in the area of bloodborne pathogens.

The 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 period would constitute a violation of this section. 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 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. This is accomplished through observation of work practices and employee interviews in an effort to determine that the training (including written material, oral presentations, films, 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,



Patricia K. Clark, Director
Directorate of Compliance Programs