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Does an online bloodborne pathogens certification count for work?

Some jobs can be expected to bring contact with blood or other materials that may be infectious. If you work in one, your employer must train you for free. A generic online course falls short unless the employer adds training on your own workplace. It also falls short if you can't reach a trainer during it. We don't know which online courses employers accept.

By State Cert GuideChecked against the sources listed below.

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The steps, in order

  1. Check your job

    Is contact with blood or other potentially infectious materials reasonably anticipated?

  2. Ask your employer

    The employer provides the training

  3. Check you can ask questions

    OSHA's letters say a trainer must be reachable during the session

  4. Repeat it

    At least annually

Steps in order: find out if your job involves occupational exposure, ask your employer for the training, check that a trainer can answer your questions while you take it, repeat the training at least annually.

What the rule says

Whose jobs does OSHA's bloodborne pathogens rule cover?

The rule applies to all occupational exposure to blood or other potentially infectious materials.

Occupational Safety and Health Administration · 29 CFR 1910.1030 · checked Nov 13, 2026 (opens agency website)

What counts as occupational exposure?

Reasonably anticipated skin, eye, mucous membrane, or parenteral contact with blood or other potentially infectious materials that may result from the performance of your duties.

Occupational Safety and Health Administration · 29 CFR 1910.1030 · checked Nov 13, 2026 (opens agency website)

Who has to provide the training?

Your employer. The employer must train each employee with occupational exposure, at no cost to the employee and during working hours. The employer must also set up a training program and make sure employees take part in it.

Occupational Safety and Health Administration · 29 CFR 1910.1030 · checked Nov 13, 2026 (opens agency website)

When do I take it the first time?

At the time of initial assignment to tasks where occupational exposure may take place.

Occupational Safety and Health Administration · 29 CFR 1910.1030 · checked Nov 13, 2026 (opens agency website)

How soon does the yearly training have to come?

What if my tasks change?

Your employer must give you more training when changes such as new or changed tasks or procedures affect your occupational exposure.

Occupational Safety and Health Administration · 29 CFR 1910.1030 · checked Nov 13, 2026 (opens agency website)

Does the training have to let me ask questions?

Yes. The training program must include an opportunity for interactive questions and answers with the person conducting the training session.

Occupational Safety and Health Administration · 29 CFR 1910.1030 · checked Nov 13, 2026 (opens agency website)

Who can teach it?

Someone knowledgeable in the subject as it relates to the workplace that the training will address.

Occupational Safety and Health Administration · 29 CFR 1910.1030 · checked Nov 13, 2026 (opens agency website)

Does the training cover my own workplace?

It must explain your employer's exposure control plan and how you can get a copy of the written plan.

Occupational Safety and Health Administration · 29 CFR 1910.1030 · checked Nov 13, 2026 (opens agency website)

What does my employer keep as proof?

What are OSHA's letters?

OSHA letters are not the text of the standard. OSHA says its letters explain what the rules require and how they apply to particular cases. It also says they cannot create additional employer obligations.

Occupational Safety and Health Administration · Interpretation letter, June 20, 2016 · checked Nov 13, 2026 (opens agency website)

Can that guidance change?

Yes. OSHA says its guidance may be affected by changes to its rules. It also says it updates guidance from time to time in response to new facts.

Occupational Safety and Health Administration · Interpretation letter, June 20, 2016 · checked Nov 13, 2026 (opens agency website)

Which letter covers generic courses, e-mail and phone lines?

A letter OSHA dated June 20, 2016. It answers a question about online training and quotes an OSHA directive.

Occupational Safety and Health Administration · Interpretation letter, June 20, 2016 · checked Nov 13, 2026 (opens agency website)

How old is the directive that letter quotes?

Is a generic online course enough?

Not by itself, according to the directive the 2016 letter quotes. It says a generic computer program, even an interactive one, is not considered appropriate unless the employer adds the site-specific details the rule requires and a person is accessible for interaction. Examples are where the exposure control plan is kept and the steps to follow if an exposure incident occurs. It adds that trainees must have direct access to a qualified trainer during training.

Occupational Safety and Health Administration · Interpretation letter, June 20, 2016 · checked Nov 13, 2026 (opens agency website)

Does an e-mail address for questions count?

Only if the trainer answers at the time, according to the same directive. It says an electronic mail system is not considered direct access to a qualified trainer, unless the trainer is available to answer e-mailed questions at the time the questions arise.

Occupational Safety and Health Administration · Interpretation letter, June 20, 2016 · checked Nov 13, 2026 (opens agency website)

Can a phone line work?

The same directive says OSHA's requirement can be met if trainees have direct access to a trainer by way of a telephone hot line.

Occupational Safety and Health Administration · Interpretation letter, June 20, 2016 · checked Nov 13, 2026 (opens agency website)

Does the rule cover people who work for themselves?

In the 2016 letter, OSHA said the Occupational Safety and Health Act covers employees, not individuals who are working only as independent contractors.

Occupational Safety and Health Administration · Interpretation letter, June 20, 2016 · checked Nov 13, 2026 (opens agency website)

Does a contract that says "independent contractor" settle it?

No, according to the 2016 letter. OSHA said merely declaring in a contract or otherwise that a hired party is an independent contractor does not automatically make the hired party an independent contractor.

Occupational Safety and Health Administration · Interpretation letter, June 20, 2016 · checked Nov 13, 2026 (opens agency website)

Does my state change any of this?

It can. The 2016 letter says State Plans must have standards and enforcement programs at least as effective as OSHA's, but may have different or additional requirements. If your state runs its own OSHA plan, check that plan's rule.

Occupational Safety and Health Administration · Interpretation letter, June 20, 2016 · checked Nov 13, 2026 (opens agency website)

Which letter covers where the trainer has to be?

A letter OSHA dated January 17, 2008. It answers a question about trainer requirements and access to a trainer.

Occupational Safety and Health Administration · Interpretation letter, January 17, 2008 · checked Nov 13, 2026 (opens agency website)

Can video training with a remote trainer work?

In the 2008 letter, OSHA said training conducted by compressed digital video, where the trainer is in one location but is in direct communication with the trainees, is an acceptable method for meeting the requirements of the standard.

Occupational Safety and Health Administration · Interpretation letter, January 17, 2008 · checked Nov 13, 2026 (opens agency website)

What if the trainer can't be reached until later?

In the 2008 letter, OSHA said employees must have direct access to a qualified trainer at the time the training is being conducted.

Occupational Safety and Health Administration · Interpretation letter, January 17, 2008 · checked Nov 13, 2026 (opens agency website)

Which letter covers e-mailed questions and a trainer on call?

A letter OSHA dated June 26, 2003. It answers questions about e-mail systems and bloodborne pathogens training.

Occupational Safety and Health Administration · Interpretation letter, June 26, 2003 · checked Nov 13, 2026 (opens agency website)

Does a trainer have to be available if I never ask anything?

Yes, according to the 2003 letter. OSHA said a qualified trainer must be immediately available to employees regardless of whether questions are actually asked, at their initial and annual training.

Occupational Safety and Health Administration · Interpretation letter, June 26, 2003 · checked Nov 13, 2026 (opens agency website)

Where people go wrong

  • You pay for a course before you ask your employer who pays. For an employee with occupational exposure, the standard says the training is at no cost to the employee.
  • You take a course with no way to ask a trainer questions as you go. OSHA's 2016 letter quotes a directive. The directive says a generic computer program is not considered appropriate unless the employer adds site-specific details and a qualified trainer is accessible during the training.
  • You rely on an e-mail form. That directive says e-mail is not direct access to a qualified trainer, unless the trainer answers at the time the questions arise.
  • You assume one course fits every workplace. The training has to explain your employer's exposure control plan, and the trainer has to know the subject as it relates to your workplace.
  • You stop after the first course. The training also comes at least annually after the first one.

Questions

I work for a staffing agency. Who trains me?

Both share it. OSHA's October 2, 1992 letter says both employers share responsibility for protecting the agency's workers. It expected the staffing company to give generic training and the client employer site-specific training. A contract could have the client employer do all the training. Even then, the staffing company is responsible for finding a way to make sure it is given. OSHA's temporary worker page says a similar split might apply. Ask your agency how it splits the training.

Who provides vaccines and protective gear to agency workers?

In that 1992 letter, OSHA expected the staffing company to make sure its employees get the required vaccinations and follow-up after an exposure. It expected the client employer to provide protective equipment and control the exposure conditions.

Does my employer have to teach the training itself?

No. In the same letter, OSHA said the training does not have to be given by the employer's own staff. An employer could arrange for a local hospital to teach it. The training still has to fit employees' language and education levels and let them ask questions.

Your next step

Before you pay for a course, ask your employer what training it provides and how you can ask the trainer questions. To read the rule itself, see OSHA's bloodborne pathogens standard. For OSHA's Outreach cards, see our guide.

www.osha.gov

Who publishes this guide

State Cert Guide is an independent guide to what each state requires. If a fact on this page is wrong, tell us and we fix it.

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