OSHA requirements are set by statute, standards and regulations. Our interpretation letters explain these requirements and how they apply to particular circumstances, but they cannot create additional employer obligations. This letter constitutes OSHA's interpretation of the requirements discussed. Note that our enforcement guidance may be affected by changes to OSHA rules. Also, from time to time we update our guidance in response to new information. To keep apprised of such developments, you can consult OSHA's website at https://www.osha.gov.

February 2, 1993

The Honorable Steve Gunderson
U.S. House of Representatives
Post Office Box 247
Black River Falls, Wisconsin 54615-0247

Dear Congressman Gunderson:

This is in response to your letter of December 22, 1992 to Mr. Frederich Drayton in which you requested a clarification of the Occupational Safety and Health Administration (OSHA) regulation 29 CFR 1910.1030, "Occupational Exposure to Bloodborne Pathogens." Your letter was referred to us for response.

Specifically, you wrote regarding the concerns of a constituent, Mrs. Lois Siefert, that "OSHA regulations now state that the Red Cross volunteers must have 5 hours of training every 90 days." This statement is incorrect. OSHA's requirements regarding the content and frequency of training are limited to paragraph (g)(2) of the standard.

Section (g)(2)(ii) specifies that training shall be provided at the time of initial assignment to tasks where occupational exposure to blood or other potential infectious materials (OPIM) may take place and at least annually thereafter. Section (g)(2)(v) states that additional training shall be provided when changes such as modification of tasks or procedures, or institution of new tasks or procedures affect the employee's occupational exposure. In this case, the additional training may be limited to addressing the new exposures created.

While the length of training is not specified, section (g)(2)(vii) lists the elements that must be included in the training program, including explanations of symptoms and modes of transmission of bloodborne diseases, location and handling of personal protective equipment, information on the hepatitis B vaccine, and follow-up procedures to be taken in the event of an exposure incident. Your constituent should bear in mind, that the training requirements of this standard are performance oriented. Compliance officers will determine, on a case-by-case basis, whether the training that has been provided is effective and adequate.

We hope this information is responsive to your concerns. If your constituent has any further questions, she may contact OSHA's regional bloodborne pathogens coordinator in Chicago, Illinois at (312) 353-2220.

Sincerely,



Roger Clark,
Director
Directorate of Compliance Programs




December 22, 1992

Mr. Frederich Drayton
Director
Office of Safety and Health
U.S. Department of Labor
200 Constitution Avenue N.W.
Washington, DC 20210

Dear Mr. Drayton:

This letter is on behalf of my constituent, Lois Siefert of Menomonie, Wisconsin regarding the Office of Safety and Health Administration rules affecting the Red Cross.

In talking with Mrs. Siefert it is my understanding that OSHA regulations now state that Red Cross volunteers must have 5 hours of training every 90 days.

Mrs. Siefert informed me that the volunteers never handle the blood and was wondering why OSHA is telling the Red Cross how to run their business. Pretty soon the Red Cross will be unable to get any volunteers because the volunteers don't want to take 5 hours of training every 90 days.

Mr. Drayton, I respectfully request your response to Mrs. Siefert's concerns. Please forward your response to my district office.

Thank you for your time and attention on this request. I look forward to your reply.

Best regards,



Steve Gunderson
Member of Congress