From the Winter 2018 Journal of the Colorado Dental Association
Q: How often is OSHA training required and which employees have to attend?
A: Annual training is required for all dental office employees who are at risk for occupational exposure. This includes exposure to bloodborne pathogens and hazardous chemicals. Given the small working environment found in most dental offices, this means all employees, including those who work up-front and in the back, have some risk and are therefore required to complete annual training. Training must be provided at the time of initial employment and at least annually (every year) thereafter.
Q: Who pays for OSHA training?
A: The employer is required to pay for OSHA training. OSHA training must be conducted at no cost to employees and must take place during normal working hours. OSHA requires employers pay for all full-time, part-time, temporary and “per diem” employee training.
Q: What qualifies as an approved OSHA training course and who qualifies to be a trainer?
A: OSHA does not approve, certify or endorse individual training programs or trainers. Instead OSHA says it is the responsibility of the employer to determine if the course and the trainer(s) meet the requirements set forth in their rules and regulations. With that in mind, below are some responses OSHA provided clarifying this topic.
OSHA specifies in the Bloodborne Pathogens Standard exactly what needs to be covered as part of annual training in sections 1910.1030(g)(2)(vii)(A) thru (N) and the Hazard Communication Standard clarifies training topics as well. The training course(s) must cover all of the required topics listed in both the Bloodborne Pathogens Standard and the Hazard Communication Standard to be considered acceptable.
As for the person conducting the training, OSHA states that persons conducting a training must be “qualified” to do so. From an OSHA letter of interpretation regarding Clarification of Competent and Qualified Person, 29 CFR 1926.32(m) states: “‘Qualified’ means one who, by possession of a recognized degree, certificate, or professional standing, or who by extensive knowledge, training and experience, has successfully demonstrated his ability to solve or resolve problems relating to the subject matter, the work, or the project.”
In addition, OSHA documents make the following statements regarding trainer qualifications:
- The person conducting the training is required to be knowledgeable in the subject matter covered by the elements in the training program and be familiar with how the course topics apply to the workplace that the training will address.
- Trainers must demonstrate expertise in the area of occupational hazards of bloodborne pathogens and it is the responsibility of the employer to determine if the trainer(s) meets the requirements and has the necessary qualifications.
- Trainers must have satisfactorily completed a training program for teaching the subjects they are expected to teach, or they shall have the academic credentials and instructional experience necessary for teaching the subjects.
- Trainers must continue to attend training in order to maintain their knowledge and skills base.
Q: Can we send one or two people from the office to an OSHA class and have them come back and train everyone else?
A: Given the lengthy explanation above on what OSHA considers a “qualified trainer,” it’s clear that attending one course does not qualify someone to be a trainer. If, however, the office has designated someone to be its “OSHA/CDC Infection Control Coordinator” and this person takes their role seriously, it is possible they are qualified to conduct the office OSHA training. This person will likely have completed several different training courses on the subjects they are expected to teach giving them the academic credentials and instructional experience necessary to become a qualified trainer. As an example, the Organization for Safety, Asepsis and Prevention offers an extensive collection of resources, courses, publications, FAQs, checklists and toolkits that help dental professionals obtain the credentials they need to become a qualified trainer. Anyone interested in becoming and maintaining their “qualified trainer” status should consider joining an organization like OSAP.
Q: Does the trainer need to physically be in the classroom or is it acceptable for the trainer to be contacted after an online training course via phone, e-mail, etc. to answer any questions employees might have?
A: OSHA has been very clear in multiple interpretations and directives that trainees must have access to the trainer during the training session. OSHA clarified that the trainer does not need to be “physically” in the classroom during the training but the trainer must be available via phone or teleconferencing at the same time the training is taking place.
Below is a clarification OSHA provided in a letter of interpretation when asked this very question.
- Question to OSHA: There are times when my employees complete an online training session when the trainer is not available, and the protocol is for these employees to leave a phone message or email the trainer and wait for a response. Is this acceptable?
- OSHA’s answer: This training scenario you describe would not meet the intent of the standard and would constitute a violation of 1910.1030(g)(2)(vii)(N). Employees must have direct access to the trainer at the time the training is being conducted allowing them the opportunity to participate in a live and interactive training session.
Q: Do we have to do spore testing?
A: Yes, spore testing must be conducted at least weekly for each sterilizer. Per CDC Guidelines for Infection Control in Dental Healthcare Settings (enforced by the Colorado Dental Board), it has been a requirement since 1993 (and upheld in the 2003 and 2016 guidelines) that spore testing must be performed at least weekly for each sterilizer. For additional information and answers to sterilization monitoring questions, visit the CDC website.
Q: Do I have to pay for vaccinations for my employees?
A: OSHA’s Bloodborne Pathogens Standard requires that employers offer and pay for the hepatitis B vaccination series and titer testing to any employee who is reasonably anticipated to have exposure to blood or other potentially infectious materials. The offer must be made within 10 days of employment and at no cost to the employee. The hepatitis B vaccine is the only vaccine that employers must pay for, however, many employers also offer and pay for annual flu vaccines as a benefit to their employees.
Q: How do I know if employees have gotten required vaccines?
A: The only vaccine employers are required to offer and document is the hepatitis B vaccine. Upon hire, the employer should have the employee complete a hepatitis B vaccination record. The employee can complete the form based on vaccine records or mental memory of past vaccine/titer history. If the employee cannot remember if they completed the series and/or they express any uncertainty about whether they were vaccinated and/or completed titer testing, they must be offered the vaccine and titer testing as if they were unvaccinated.
