August 28, 1996

Jeffery A. Reynolds, CIH
Director, Industrial Hygiene
PMK Group
Consulting Engineers
629 Springfield Road
Kenilworth, New Jersey 07033

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



July 22, 1996

Mr. John Miles
Director of Compliance Programs
U.S. Department of Labor
Occupational Safety and Health Administration
200 Constitution Avenue N.W.
Washington, DC 20210

Dear Mr. Miles

We have a health care client that is interested in conducting various OSHA required training through the use of video tape presentations. Some of their staff have questioned such training being conducted without the physical presence of a "competent" person to answer questions.

We believe the OSHA standards are silent relative to the physical presence of the "competent" person at the training session. But that compliance with the standards depends upon the content of the training program meeting the requirements of the standard in conjunction with the ability of a trained employee to demonstrate their competency in the subject matter.

If, the training program addresses required issues, and the employees trained through the program are capable of demonstrating their competency, would not the training requirements of the standards have been met?

Thank-you in advance for your time and consideration in responding to the issue we have raised. Please forward any response to me through the PMK Group, 629 Springfield Road, Kenilworth, New Jersey, 07033.

Sincerely, PMK Group

Jeffery A. Reynolds, CIH
Director, Industrial Hygiene