The US department of labor estimates that 5.6 million workers risk exposure to bloodborne pathogens, including human immunodeficiency virus (HIV), hepatitis B virus (HBV), and hepatitis C virus (HCV), while on the job. An OSHA Standard Bloodborne Pathogens (1910.1030) Training Program is essential for any person who may be “reasonably anticipated” to face contact with blood and other potentially infectious materials as the result of performing their job duties. Professions at risk include, but are not limited to, healthcare professionals, educators, cosmetologists, tattoo artists, and construction workers. Industries whose employees have contracted infection from bloodborne pathogens while on the job run the risk of an OSHA citation up to $70,000 for facilities not in full compliance with bloodborne pathogens standard.

The Occupational Safety and Health Administration (OSHA) has recently begun to strictly enforce the bloodborne pathogens standard. Facilities not in full compliance with the standard, including failure to provide proof of OSHA standard bloodborne pathogens training to all employees, have received up to 70,000 dollars in fines.

A Bloodborne Pathogen program should include, but not be limited to:

• Exposure Control
• Methods of Compliance
• Personal Protective Equipment
• Housekeeping
• Regulated Waste Control
• Communication of Hazards to Employees
• Recordkeeping

It is the employers’ responsibility to train and inform their employees about hazards in the workplace.  It is also the responsibility of the employer to pay for all PPE necessary to keep the employee safe.

The Compliance Resource Center provides training and polices and procedures for Bloodborne Pathogens Programs and other OSHA and DOT compliance.

Requirements for employers to train employees exist throughout U.S. OSHA standards. However, some employers and, apparently, some OSHA inspectors, are not aware that training must be conducted in a manner that the employee can understand.

OSHA’s general policy is that if an employee receives job instructions in a language other than English, training and information must also be conveyed in that language. Similarly, says OSHA, if the employee’s vocabulary is limited, the training must account for that limitation. Furthermore, if employees are not literate, telling them to read training materials will not satisfy the employer’s training obligation.

“As a general matter, employers are expected to realize that if they customarily need to communicate work instruction or other workplace information to employees at a certain vocabulary level or in a language other than English, they will also need to provide safety and health training to employees in the same manner,” says OSHA.

OSHA adds that its training provisions contain a variety of specific requirements to ensure that employees are comprehending instruction. For example, standards covering lockout/tagout, respiratory protection, and bloodborne pathogens each require that employers take measures to ascertain the level to which the employee has comprehended the safety provisions.

In its instructions to inspectors, OSHA states, “If a reasonable person would conclude that the employer had not conveyed the training to its employees in a manner they were capable of understanding, then the violation may be cited as serious.”