Over that past couple of years, I've talked to many people who've had some misconceptions about OSHA and their requirements for Medical Courier Training, or Bio hazard Awareness Training.
I talked to one company on the west coast who said, " I use independent contractors and we can't tell them how to do their job or what kind of training to receive, so we just don't bother with it."
When I asked him if his company was OSHA Compliant to handle medical specimens, he replied,"Stop it! You're scaring me already!"
Another person from the east cost told me when I called her that, "Your training course is so expensive, we found a download on the internet for a fraction of that cost and we'll just train our drivers with that."
Still another company owner from the south told me, "Aww, we'll just do the training ourselves. I mean, it's not rocket science or anything."
I have long wanted to post some of the actual OSHA regulations so that company owners or IC's can come online and get the facts for themselves.
So here goes:
Does your trainer have an understanding of the dangers present with medical specimen deliveries and does he/she know how to equip the drivers to properly protect themselves from exposure?
1. Paragraph (g)(2)(vii)(F). This paragraph requires that training include an explanation of the use and limitations of methods that will prevent or reduce exposure, including appropriate engineering controls, work practices, and personal protective equipment.
This requirement is very important, because the development of safer engineering controls introduces a variety of new techniques and practices to the work environment. The Record Summary respondents "repeatedly" emphasized the necessity of effective training and education whenever new engineering controls are implemented. Training must include instruction in any new techniques and practices.
"Hands-on" training is particularly useful. Employee participation in the selection of new devices, which plays a major part in their acceptance and correct use, is also required. (See above discussion in paragraphs (c)(1)(iv), (c)(1)(v) and (d)(2) on engineering and work practice controls.)
Having performed thousands of specimen deliveries over 29 years, my training program is very thorough in explaining and illustrating the safest and most effective ways to transport medical specimens.
Does your current training program offer live fully interactive training with opportunity for questions and answers?
3. Paragraph (g)(2)(vii)(N). This paragraph requires that there be an opportunity for interactive questions and answers with the person conducting the training session. (So much for internet downloads.....)
During training, it is critical that trainees have an opportunity to ask and receive answers to questions where material is unfamiliar to them. Frequently, a trainee may be unable to go further with the training or to understand related training content until a response is received.
Once again, over the years I have come across numerous situations that required action and I use these experiences to guide and advise the trainees how to correctly respond based on my personal experiences.
With our live-interactive Webinars, each and every question is answered immediately by me, the trainer.
Training the employees solely by means of a film or video without the opportunity for a discussion period would constitute a violation of this paragraph.
Similarly, a generic computer program, even an interactive one, is not considered appropriate unless the employer supplements such training with the site-specific information required (e.g., the location of the exposure control plan and the procedures to be followed if an exposure incident occurs) and a qualified person is accessible for interaction.
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 hot line. 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-mailed questions at the time the questions arise.
While there are "bio-hazard training modules" out there that you can download at a cost saving to your company, they are NOT OSHA Compliant because there is not the opportunity for questions and answers from a qualified individual and in most cases they are NOT courier specific.
Is your bio hazard trainer qualified according to OSHA to teach the materials with the proper background and training themselves?
4. Paragraph (g)(2)(viii). The person conducting the training is required to be knowledgeable in the subject matter covered by the elements contained in the training program as it relates to the workplace that the training will address. ( in other words, courier specific.) In addition to demonstrating expertise in the area of the occupational hazard of blood borne pathogens, the trainer must be familiar with the manner in which the elements in the training program relate to the particular workplace.
The Compliance Officer should verify the competency of the trainer based on the completion of specialized courses, degree programs, or work experience, if he/she determines that deficiencies in training exist.
Possible trainers include a variety of health care professionals such as infection control practitioners, nurse practitioners, registered nurses, occupational health professionals, physician's assistants, and emergency medical technicians.
I worked for 20 years as a medical courier for the nation's largest clinical laboratory as a driver and ultimately as a "driver-trainer."
The training and experience I received as such has qualified me to train and pass on my extensive knowledge to couriers across the country.
I have owned 2 successful medical courier companies in the midwest, and currently operate my 3rd in Colorado, so we are actually serving clinical lab clients on a daily basis.
We assume the responsibility for assuring that your drivers are trained according to OSHA guidelines and we update the training materials on a regular basis.
That way, your company can concentrate on growing your business and not on the special training needs of couriers who transport medical specimens.
These are just a few of the common misconceptions some people make in deciding how they are going to train their drivers and try and remain OSHA compliant.
More to come....