OSHA Bloodborne Pathogens Training Requirements

Short answer: under OSHA’s Bloodborne Pathogens Standard, 29 CFR 1910.1030(g)(2), every employee with occupational exposure to blood or other potentially infectious materials must be trained at initial assignment, at least annually (within one year of the last session) and when tasks change, at no cost and in working hours. The training must cover 14 listed elements, ending with an opportunity for interactive questions and answers with the trainer, and the records (dates, content, trainer and qualifications, attendees and job titles) are kept three years. Checked October 10, 2026 against eCFR and osha.gov; not legal advice.

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Who must be trained

“The employer shall train each employee with occupational exposure” (1910.1030(g)(2)(i)). Occupational exposure means “reasonably anticipated skin, eye, mucous membrane, or parenteral contact with blood or other potentially infectious materials that may result from the performance of an employee’s duties” ((b)). Training must be provided at no cost to the employee and during working hours ((g)(2)(i)).

Your written exposure determination decides who that is: a list of job classifications in which all employees have occupational exposure, a list of those in which some do, and the tasks and procedures that cause the exposure, made without regard to personal protective equipment ((c)(2)). In practice:

• Dental offices: the standard lists “saliva in dental procedures” as other potentially infectious material ((b)), so hygienists, assistants and dentists are the obvious group; anyone who cleans or sterilizes instruments too.
• Medical offices and urgent care: staff who draw blood, give injections, handle specimens or clean contaminated instruments.
• Veterinary clinics: the standard defines blood as human blood, and its list of other potentially infectious materials covers human body fluids and tissues and, for animals, only material from experimental animals infected with HIV or HBV ((b)). Whether any clinic employee has occupational exposure therefore depends on human-blood tasks, such as first aid, and belongs in your own exposure determination.

When: initial, annual and when tasks change

• At initial assignment to tasks where occupational exposure may take place ((g)(2)(ii)(A)), so before the first chairside or phlebotomy shift.
• At least annually ((g)(2)(ii)(B)), and “within one year of their previous training” ((g)(2)(iv)). A calendar-year habit (January one year, December the next) can miss that.
• When tasks or procedures change in a way that affects the employee’s exposure; that extra training may be limited to the new exposure ((g)(2)(v)).

The material must suit the employees’ educational level, literacy and language ((g)(2)(vi)), and the trainer must be knowledgeable in the subject matter as it relates to your workplace ((g)(2)(viii)).

What the training must cover: elements (A) to (N)

1910.1030(g)(2)(vii) sets the minimum content. Use it as the agenda:

1. (A) An accessible copy of the regulatory text of the standard and an explanation of its contents.
2. (B) The epidemiology and symptoms of bloodborne diseases.
3. (C) The modes of transmission of bloodborne pathogens.
4. (D) Your exposure control plan and how employees can get a copy.
5. (E) How to recognize tasks and activities that may involve exposure to blood and other potentially infectious materials.
6. (F) The use and limitations of engineering controls, work practices and PPE.
7. (G) Types, proper use, location, removal, handling, decontamination and disposal of PPE.
8. (H) The basis for selecting PPE.
9. (I) The hepatitis B vaccine: efficacy, safety, method of administration, benefits, and that it is offered free of charge.
10. (J) What to do and whom to contact in an emergency involving blood or other potentially infectious materials.
11. (K) The procedure after an exposure incident, including how to report it and the medical follow-up available.
12. (L) The post-exposure evaluation and follow-up the employer must provide.
13. (M) The signs, labels and color coding required by (g)(1); see sharps containers and biohazard labels.
14. (N) “An opportunity for interactive questions and answers with the person conducting the training session.”

Online courses and the live Q&A requirement

Element (N) is where off-the-shelf online courses usually fall short. In a 1992 letter OSHA said that a generic program, “even an interactive computer program”, must be supplemented with site-specific information and that a person must be accessible for interaction with trainees; the trainer need not be in the room, and telephone access may work depending on how reachable the trainer is (OSHA interpretation, April 16, 1992). A 1997 letter added that computer-based training by itself would not meet the intent of most OSHA training requirements, and that a telephone hotline giving trainees direct access to a qualified trainer may meet the question requirement (OSHA interpretation, June 11, 1997). A workable pattern for a small office: an online module for the general content, then a short in-house session on your own plan, sharps containers, PPE and exposure procedure, with a knowledgeable person answering questions.

Training records: what to keep, and for how long

1910.1030(h)(2)(i) requires training records to include:

• the dates of the training sessions;
• the contents or a summary of the training sessions;
• the names and qualifications of the persons conducting the training;
• the names and job titles of all persons attending.

Keep them three years from the date of the training ((h)(2)(ii)), and provide them on request to employees, employee representatives and OSHA ((h)(3)(ii)). Medical records under (h)(1) (hepatitis B vaccination status, post-exposure evaluations) are different: confidential, and kept for the duration of employment plus 30 years ((h)(1)(iii)–(iv)).

The duties that travel with the training

• Exposure control plan. A written plan, accessible to employees, reviewed and updated at least annually ((c)(1)). Walk through it in every session (element D). Outline: exposure control plan requirements.
• Hepatitis B vaccination. Made available, at no cost, after the employee has received the training in element (I) and within 10 working days of initial assignment, unless the employee has already had the series, is immune, or the vaccine is medically contraindicated ((f)(1)(ii)(A), (f)(2)(i)). An employee who declines signs the declination statement in Appendix A ((f)(2)(iv)) and can still accept the vaccine later ((f)(2)(iii)).
• Sharps injury log. Required of any employer that must keep injury and illness records under 29 CFR Part 1904 ((h)(5)(ii)); it records the type and brand of device, the work area and how the incident happened, protects the employee’s confidentiality ((h)(5)(i)), and is kept as long as the OSHA 300 log ((h)(5)(iii)). Offices of dentists (NAICS 6212) and physicians (6211) are on OSHA’s partially exempt list (Part 1904 Subpart B, Appendix A), so they keep neither unless OSHA or BLS asks in writing; veterinary services are not on that list. See the OSHA 300 log and do I need an OSHA 300 log?
• HazCom training is separate. Disinfectants, sterilants, etchants and amalgam are chemicals under 29 CFR 1910.1200, and HazCom excludes biological hazards. One annual session can cover both, but the records should show both topics; see HazCom training requirements.

How SDSentry fits, and what it does not do

SDSentry is HazCom software: an SDS library, GHS labels, a written HazCom program and training records. It is not a bloodborne pathogens course and it does not write or review your exposure control plan. What it can do for a practice that already runs its own bloodborne pathogens training:

• Keep the (h)(2) training record. On the Training tab, Add training record has a Type selector: HazCom, Bloodborne pathogens or Other. With Bloodborne pathogens selected, the form asks for, and will not save without, the employee’s name and job title, the topic, the training date, the trainer’s name and qualifications, and the contents or a summary of the session: the four elements 1910.1030(h)(2)(i) lists. The retraining-due date defaults to one year after the training date unless you set another, and the record shows as expired when that date passes. An admin can capture a typed e-signature on the record, which is stored with a timestamp. One record covers one employee, so for a group session add a record for each attendee with the same date, summary and trainer.
• What it prints and exports. The printable record for a bloodborne pathogens entry is titled Bloodborne Pathogens Training Record, cites 29 CFR 1910.1030(g)(2) and (h)(2), and prints the date, the contents or summary, the trainer’s name and qualifications, and the attendee’s name and job title. HazCom records keep the Hazard Communication acknowledgment (29 CFR 1910.1200(h)). The training CSV export and the account JSON export include the training type and the three bloodborne pathogens fields. When you assign a bloodborne pathogens training, the email to the employee is worded for bloodborne pathogens, mentions the at-least-annual requirement and has no HazCom wording.
• Completing a self-signed record. If an employee completes a bloodborne pathogens assignment themselves on their My Training page, they sign it and enter their job title, but the session summary and the trainer’s name and qualifications are not captured there. The Training tab flags such a record with Complete BBP record: an admin opens it, fills in the missing elements and saves, and the printed record then shows every (h)(2)(i) element. Any training record can be edited the same way (topic, type, dates, trainer, qualifications, summary, job title); the employee’s name and the e-signature cannot be changed. When a record was already e-signed, the signature stays as captured and the printed record lists which fields an admin completed or changed after signing, and when.
• What it does not do for you. The interactive question-and-answer part of the training has to happen in your session, not in SDSentry.
• Records are archived, not erased. Archiving a training record moves it to an archived list that an admin can restore, which helps you keep the three years (h)(2)(ii) requires.

• Needlesticks on the OSHA 300 log. SDSentry’s Injury log tab records 300 and 301 cases per location. Its privacy-case box lists “contaminated needlestick or sharps” among the privacy concern cases; ticked, the printed 300 shows “Privacy case” instead of the name and SDSentry prints the separate confidential list 1904.29(b)(6) requires. It has no separate sharps injury log form and no sharps filter. If you use the 300 log as your sharps log, as OSHA’s FAQ allows, type the device type and brand into the case and keep sharps cases easy to separate. See the OSHA 300 log guide.
• SDS library. Keep the safety data sheets for the disinfectants and sterilants your training refers to (for example CaviWipes, Clorox Healthcare bleach wipes, glutaraldehyde) in the same account.

Printable session checklist

• Exposure determination current; everyone on it scheduled (new hires before first exposure task).
• Last session for each person less than 12 months ago.
• Copy of 1910.1030 available in the session; elements (A)–(N) on the agenda.
• Your exposure control plan explained and its location shown.
• Hepatitis B vaccine information given; vaccination offered or declination signed.
• A knowledgeable person available for questions (in person or reachable).
• Sign-in sheet with names and job titles; agenda or summary; trainer name and qualifications; kept 3 years.

Bloodborne pathogens, sharps and amalgam: the full set

• Exposure control plan: what it must contain
• Sharps container and disposal requirements
• Dental amalgam separator rule (EPA, 40 CFR 441)

By practice type: dental offices, oral surgery and orthodontic offices, medical offices and urgent care and veterinary clinics.

Sources (checked October 10, 2026)

• eCFR, 29 CFR 1910.1030 Bloodborne pathogens — (b) definitions; (c) exposure control; (f) hepatitis B vaccination; (g)(2) information and training; (h) recordkeeping (eCFR current as of October 7, 2026). Also at osha.gov.
• OSHA interpretation letter, April 16, 1992 — generic or computer programs must be supplemented with site-specific information and an accessible person.
• OSHA interpretation letter, June 11, 1997 — computer-based training alone; a telephone hotline to a qualified trainer.
• 29 CFR Part 1904, Subpart B, Appendix A — partially exempt industries (6211, 6212 listed).
• 29 CFR 1904.8 — recording needlestick and sharps injuries; OSHA FAQ 8-2 — using the 300 log as the sharps injury log.
• OSHA: Bloodborne Pathogens and Needlestick Prevention.

Educational information only, not legal or compliance advice. Quotations and citations are from the current eCFR text and the agency pages listed above, checked October 10, 2026. State Plan states and state and local agencies can add to these requirements; verify with them or consult a qualified professional.