Home

Keep an eye on OSHA interpretation letters

The following is a list of clarifications from OSHA that came out in 2007:

Annual bloodborne pathogen training is required regardless of the employees’ prior training or education. Refresher training does not have to be an exact repetition of the initial training.
Annual training need not be performed on the exact anniversary date of the preceding training but should be provided on a date reasonably close to the anniversary date. Employers who miss the annual training date should record why the training is delayed and when it will be provided.
Urine containers and pregnancy tests that do not contain visible blood do not required biohazard (red bag) disposal.
Employers are responsible for evaluating the need for personal protective equipment, not a manufacturer’s claim.
First aid must be available within three to four minutes whether using in-house or outside emergency services.
Every employer must have a written, dated record of each dose of hepatitis B vaccination, even if that means contacting an employee’s previous employer.
Bloodborne pathogen training must be provided in a manner that the recipient is able to understand. This includes non-English-speaking or limited-English-proficient employees.
Gloves must be changed between patient contacts.