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Q. We presently use a computer program that’s developed each year by our education department for training on the bloodborne pathogen standard by the Occupational Safety and Health Administra-tion (OSHA). It contains photos and telephone numbers of persons to contact for questions or information. Does this meet OSHA requirements?
A. The development of and use of a facility-specific training program does meet the OSHA requirement; however, OSHA is clear that there must be "direct access" to a qualified trainer for questions. In the new compliance directive issued on Nov. 5, 1999, OSHA has spelled out what is meant by this statement on pages 62-63. "Trainees must have direct access to a qualified trainer during training. OSHA’s requirement can be met if trainees have direct access to a trainer by way of a telephone hotline. The use of an electronic mail system to answer employee questions is not considered direct access to a qualified trainer, unless the trainer is available to answer e-mail questions at the time the questions arise."
Therefore, if training is viewed by the night shift at 3 a.m., then the trainer needs to be available at 3 a.m. via phone or e-mail to answer any questions.
—Answer by Katherine West, BSN, MSEd, CIC, Infection Control Consultant, Infection Control/Emerging Concepts, Manassas, VA.