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Who Needs Bloodborne Pathogens Training?

Under OSHA's Bloodborne Pathogens standard, 29 CFR 1910.1030, the training duty belongs to the employer. An employer must train each employee with occupational exposure to blood or other potentially infectious materials, at no cost and during working hours. Training is due when the employee is first assigned to exposure tasks and at least once a year after that. It must include a chance to ask questions of the person conducting the training, and OSHA has said that means direct access to a qualified trainer during the session.

Updated October 24, 2026 · Checked against the official sources listed at the end

Who the standard covers

The standard applies to all occupational exposure to blood or other potentially infectious materials (1910.1030(a)).

OSHA defines occupational exposure as 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. The test is the job's duties, not a job title.

The rule is written for employers and their employees. If you are a student, an applicant or a contractor, your program, clinical site or client decides what training it accepts from you. Ask them.

The employer's training duty

Section 1910.1030(g)(2)(i) says the employer must train each employee with occupational exposure. The training must be provided at no cost to the employee and during working hours. The employer must set up a training program and make sure employees take part.

At the time of initial assignment to tasks where occupational exposure may take place (g)(2)(ii)(A).
At least annually after that (g)(2)(ii)(B), and within one year of the previous training (g)(2)(iv).
Additional training when changes in tasks or procedures affect the employee's exposure. It may be limited to the new exposures (g)(2)(v).
Material suited to the employees' education level, literacy and language (g)(2)(vi).

What the training must cover

Section 1910.1030(g)(2)(vii) lists the minimum content. Several items are about the employer's own workplace, not bloodborne diseases in general.

An accessible copy of the standard and an explanation of it.
The epidemiology and symptoms of bloodborne diseases, and how they are transmitted.
The employer's exposure control plan and how to get a copy of it.
How to recognize tasks that may involve exposure, and the use and limits of engineering controls, work practices and personal protective equipment (PPE).
PPE types, use, location, removal, handling, decontamination and disposal, and why that PPE was chosen.
The hepatitis B vaccine, including that it will be offered free of charge.
What to do and whom to contact in an emergency, how to report an exposure incident, and the follow-up the employer must provide.
The required signs, labels and color coding.
An opportunity for interactive questions and answers with the person conducting the training session.

Online training and the question-and-answer rule

The last item on that list, (g)(2)(vii)(N), is the one online training often runs into.

In a June 26, 2003 interpretation letter, OSHA answered questions about workbook and online bloodborne pathogens training. OSHA said employees must have direct access to a qualified trainer during the training session. Answering emailed questions later does not count unless the trainer is available to answer them at the time they come up. A referral to someone else does not count unless that person is immediately available and is a knowledgeable trainer. And a qualified trainer must be immediately available even if no one asks a question.

In plain terms: under OSHA's reading, an online course by itself, without a qualified trainer the employee can reach during the session, does not meet the standard's training requirement. The rule also says the trainer must know the subject as it relates to the workplace the training covers (g)(2)(viii). The employer still has to cover its own exposure control plan, PPE and procedures.

Training records

Employers must keep training records for 3 years from the date of the training (1910.1030(h)(2)(ii)).

Dates of the training sessions.
The contents or a summary of the training.
Names and qualifications of the people who conducted it.
Names and job titles of everyone who attended.

Where an online course fits

OSHA says it does not approve, certify, or endorse individual trainers or training programs. So no course is "OSHA approved."

Pact sells the Healthcare Bloodborne Pathogens course for $34.95. Healthcare Bloodborne Pathogens is an online certification course from ProTrainings. Confirm with your program or clinical site that this course meets its requirements before you enroll. ProTrainings makes and runs the course; Pact sells it and handles your order. Buyers must be 18 or older.

If you are an employer, remember that the duties above are yours, including trainer access and the parts about your own workplace.

Common questions

Is bloodborne pathogens training required every year?

For employees with occupational exposure, yes. OSHA requires training at initial assignment and at least annually after that, within one year of the previous training (1910.1030(g)(2)(ii) and (iv)).

Can an employer charge employees for bloodborne pathogens training?

No. The standard says the training must be provided at no cost to the employee and during working hours (1910.1030(g)(2)(i)).

Is online bloodborne pathogens training enough for OSHA?

Not on its own. The standard requires an opportunity for interactive questions and answers with the person conducting the training. OSHA's 2003 interpretation says employees must have direct access to a qualified trainer during the session.

Is there an OSHA-approved bloodborne pathogens certification?

No. OSHA says it does not approve, certify, or endorse individual trainers or training programs.

I'm a nursing or allied health student. Do I need this training?

Ask your program or clinical site. OSHA's rule is written for employers and employees, so your program or site decides what training it accepts from students.

How long must employers keep bloodborne pathogens training records?

Three years from the date of the training (1910.1030(h)(2)(ii)).