#224 Is Your Bloodborne Pathogens & Infection Control Training Up to Par?

In this episode, the Divas review the topics that must be covered in BBPS training, when it must be provided and who is qualified to present the training. Learn from the experts how to manage new employee and annual training on the BBPS, infection control and other required safety training.

Resources:

• OSHA BBPS Fact Sheet - https://www.osha.gov/sites/default/files/publications/bbfact01.pdf 
• OSHA Bloodborne Pathogens and Needlestick Prevention  https://www.osha.gov/bloodborne-pathogens/resources
• CDC Information for Employers - Complying with OSHA's Bloodborne Pathogens Standard   https://www.cdc.gov/niosh/docs/2009-111/pdfs/2009-111.pdf                                  

                                                 https://www.thecompliancedivas.com

Transcript

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SPEAKER_00 0:04

Welcome. I'm Leslie Cannon. I'm Mary Gavoni. I'm Linda Harvey.

SPEAKER_02 0:10

I'm Olivia Wan, and together we are the Compliance Divas. Welcome to the Compliance Divas podcast. I'm Mary Gavoni and I'll be the moderator for this episode. And we're going to take a look at OSHA required training, in particular for bloodborne pathogens or infection prevention and control. But we also have to consider that we also need to have hazard communication or chemical safety training as well. Since the pandemic put us sort of on high alert for infection control and prevention training, the end of the pandemic, I think, kind of sent us back into a little bit of a complacent state in terms of infection prevention and control. So what we want to do again is look at what are our training practices? Are we doing the best? Are we doing what OSHA expects? And we're going to start off with Linda, who's going to talk about OSHA Bloodborne Pathogens training.

SPEAKER_01 1:13

Thanks for bringing this topic up, Mary. I think a lot of offices are fulfilling this requirement, or if they get behind, they know it's something that needs to be on the radar. But let's give them some tips to be sure they're fulfilling it properly. So, first and foremost, the training has to be offered upon hire with new hires. We don't wait to postpone our annual training two or three months because we're hiring somebody next month. The training has to be very specific upon hire. And it doesn't have to be a huge course that you send them to. If you're qualified in office, you can certainly do the training yourself in office and fill out the appropriate new hire forms that you should find in your OSHA manual. That being said, with annual training, Mary, we all remember that this is 12 months from your last training because OSHA doesn't say annually. The bloodborne pathogen standard is very specific in that it states it has to be 12 months or one year from the date of the last training, actually. And so while you may not have the perfect same date every year, you do want to stay within a narrow window of time. A couple weeks or so each way would keep you in that time frame. It would not be an appropriate time frame if you had training in November of one year, and then the next year you skip November because everybody was sick or your trainer was not available or whatnot, and then you don't do it for another year, you've missed a calendar year. You've missed a whole calendar year of training. So if you were to be inspected, an OSHA officer or an auditor would be looking at your training and the training dates. So try to have them as consistent as possible. And another thing that's often missed Mary is just when we think about training and glossing over it a little bit too much, is that the Bloodborne Pathogen Standard has a very specific section on training. And we're talking about the standard 1910.130 and it's paragraph G. It's a very not particularly long section, but it lists out the different 14 points that are supposed to be included every year for annual training. And when those are covered, then we fulfill the obligation. And while that might seem cut and dry, that oh, I could do this with a video, I could just read it, I could do a self-study. Some of the course information, of course, hasn't changed, but there is a different approach to take every year. The fact that, you know, the epidemiology and symptom of bloodborne diseases, maybe that is consistent, but there's different modes of transmission, there's different pathogens that are evolving every year. And we need to take into account, Mary, about situational learning for every office. There's no way you can discuss scenarios and what-ifs and what's actually happening in your practice through a recorded training, for example. So I'm just going to highlight a few of these. I'm not going to list out all four, but we do have a resource from our Diva Leslie that we will include with the 14 points. So we have to have an explanation or cover of an area that's called an explanation of the appropriate methods for recognizing tasks and other activities that may involve exposure to blood and other potentially infectious materials. So, what are those exposures? Those are things that would vary from practice to practice. So those are things that you want to be sure that you're that you're talking about uniquely to your practice, as well as the required element for the explanation of the use and limitation of methods that will prevent or reduce exposure. The engineering controls in every practice are not the same. And the work practices vary because the operatories are set up differently, the layout of the practice is different. So while we're all using very similar PPE, there might be some nuances from practice to practice. And that might be missed in some of the canned training, so to speak, Mary. So thanks for bringing up this topic today.

SPEAKER_02 4:52

Thank you, Linda. And I I love the concept of situational learning because in the bloodborne pathogen standard, it says that the training must be relevant for the procedures that are done in a particular practice. So, Leslie, can you talk to us a little bit about who can present the training? Does it have to be an outside person coming in? Can it be somebody on the team? Who is qualified to be a trainer according to OSHA?

SPEAKER_00 5:20

Well, Mary, OSHA says that bloodborne pathogen training can be provided by a variety of qualified individuals or even organizations, including an employer's own qualified personnel, third-party trainers, or an OSHA education center. But the key requirement is that the training must be provided by someone who has the necessary expertise to fully explain the modes of transmission, recognition of tasks with the potential exposure, and very important, post-exposure procedures. And that person has to be familiar with the setting. So when a team member is appointed as, let's say, the OSHA coordinator for a practice, they would be the best individual to be able to provide that training if the employer is going to have someone on their own team do that.

SPEAKER_02 6:13

That really makes it very clear, I think, Leslie. Thank you so much. And I know a lot of practices right now are struggling with increased costs. And again, in sort of that complacency mode that some people are in, is like, oh, yeah, we got to do this training every year and it's boring and we know this stuff. I think there's the idea that, you know, let's make this as quick and painless as possible. And sometimes we watch the same training video from one year to the next, which is not a bad idea in terms of enforcing or reinforcing concepts, but it doesn't allow for any kind of updates. As Linda alluded to, there may be new pathogens we need to worry about. We've had a lot of developments in infection control in terms of respiratory diseases and so forth. Are we keeping up with that? And I've heard, as many of our colleagues have heard from practices that say we watch the same video every year, and now the team could repeat it themselves because they know it so well. So, on one hand, yay, but on the other hand, we're not getting any new information. And teams are looking right now for cost-effective alternatives. There are a number of sales reps that are doing this for their companies, for the distributors that are doing it as a no-cost training and so forth. And we just want to make sure that if that's the avenue that you're pursuing, is it really meeting the OSHA requirements? So, Leslie, can you kind of expound on that a little bit for us, please?

SPEAKER_00 7:49

Yes, Mary. And one thing I want to bring up before I forget is that OSHA can ask for three years of records of blood-borne pathogen training. So, as important as you mentioned earlier, if you had skipped, let's say you skipped in November and went to the following November, you cannot reproduce what training you did not perform. So it's very important to have that annually. And when we do look at some of the other options for training, first of all, where do the trainers get their training? Have they been going to the Association for Dental Safety meetings? Are they, do they understand OSHA for dental offices that way? Are they authorized by the federal government as an OSHA outreach trainer? Or are they just looking at a book and trying to do a book report, so to speak? So it's important that we try to find out ahead of time how is this person that may be coming in and offering us free training, how are they qualified to do it and what requirements are they going to meet for us? Do they know our practices specifically? Do they know where our fire extinguisher is, where our first aid kit is? Can they give us some tips on the eyewash station and how to check that? And be do they make it personalized for us? And I know that, well, for yourself and Olivia and Linda and I, we're very strict on making sure that OSHA compliance is in place. And where it's not, we provide a checklist or a to-do list or or how to come up with corrective action to help dental teams be compliant and be safe. So knowing that the trainer has some experience with your site specific practice and where everything is, and then knowing that they have the ongoing education and they continue their ongoing education to bring that back to the practice is so important.

SPEAKER_02 9:48

Great points, Leslie. It it really is something that we shouldn't take for granted. Many teams are aware, but many teams are unaware that we've got some changes coming now from the hazard communication standard that was passed in 2024, and we need to start in 2026 compiling updated safety data sheets and chemical inventory and doing some training. So it is important to make sure that you either utilize resources or have the internal resources to be able to do that training. Linda.

SPEAKER_01 10:47

So you can talk about what everybody's doing, it's how it can be adapted to the situational learning and customized for each practice. And that's what so many consultants like us are so good at doing. And so using an outside resource has quite a few benefits to that. So I think that's something that our team should keep in mind when that happens. To be every now and then, at least every year, maybe every year, use somebody outside to be able to augment with that additional information, especially when there changes, as you mentioned, because the first employer deadline in 2026 is July. So while it seems like a ways away, the things that need to be done need to be planned now and implemented as soon as possible.

SPEAKER_02 11:26

You're absolutely right, Linda. And sometimes it's just better to have another pair of eyes take a look at what is happening in a practice, things that many people overlook or they just take for granted because we see these things happen every day. But the bottom line is as we approach the end of the year, and there may be either some downtime or some planning, some strategic planning for the pre for the next year, the upcoming year, that we look at how we can make ourselves the safest place for us and for our patients. Because if we hold ourselves out as a practice that values safety and the best patient care, then we need to be walking the talk. And by continuing with good training, good content, and really looking at do we need to make changes or do we have some things to celebrate that we do really well? That is a key part of that. Leslie, anything to add?

SPEAKER_00 12:29

You know, I also wanted to add that if a team does decide to go it alone on doing the training and have somebody on staff do the training, maybe they're watching a video, but always leave time for discussion with the trainer for questions. That is one key element that OSHA would look into if you're watching a video, has to have been some time built in to communicate with the trainer and ask questions and like you said, do a recalibration, look for things that that maybe we overlook throughout the year. Sometimes we get a little sloppy with our PPE. And one thing I like to say to teams is that if we aren't wearing our PPE the right way, let's say mask below the nose type of thing, or not wearing a clinical jacket, patients know a lot about PPE these days, and they're going to wonder if we can't protect ourselves, how are we going to protect them? And so it all adds to the culture of safety and compliance and making sure that we do have an adequate amount of time to look at things from the eyes of a patient or from the eyes of an outsider. I always like to think about when I go to somebody's house, I remember seeing a spot on their carpet as I walked in the door. And my eyes went right to that spot on the carpet. However, they've been overlooking it for years because it's just part of their normal everyday living. So in our dental settings, sometimes a real eyesore can be something our patients see immediately. An OSHA auditor might see immediately, but we just don't see it any longer.

SPEAKER_02 14:07

Great point, Leslie. Thank you. And that's a great way to sum up. So we thank you for joining us for this podcast, and we hope that we stimulated some thoughts and some discussion about how best to train the team so that you can be at your best, so that you can have the safest environment for you and your patients. The Compliance Divas brings clarity and simplicity to compliance by navigating the regulatory world to keep you on course. You can submit questions by email to support at thecompliancedivas.com. We will have resources in the show notes from today's discussion. And please scroll down at the end of the podcast and leave us some comments or feedback or a review. We appreciate you all, and we'll see you in our upcoming episodes.