Computer-based training not up to OSHA bloodborne pathogen standard
Program must allow for real-time Q&A
Technology has opened new avenues for health and safety training, but it comes with a caveat: Computer-based modules may not meet the requirements of the bloodborne pathogen standard.
The U.S. Occupational Safety and Health Administration (OSHA) requires employers provide "direct access to a qualified trainer during training," which can include e-mail only if the trainer is available to respond to the e-mail immediately.
"We don't want the person to have lost their answer or not have their questions answered," says Dionne Williams, MPH, industrial hygienist and team leader in the OSHA Office of Health Enforcement. "It has to be done in a way that employees still have the same opportunities they would if they were sitting in a classroom."
OSHA cites about 10 employers each year for failing to have real-time access to a trainer who can answer questions related to computer-based training, she reports.
"What we require is that at the time they're doing the computer-based training that there is the opportunity to contact someone," Williams says. "Telephone contact would be fine. What we would consider inappropriate would be someone doing training off-hours and the person who would be the appropriate trainer is not on shift and has to get back to the person."
Despite that issue, computer-based training remains appealing because it adds an element of flexibility and accountability, says William G. Buchta, MD, MPH, medical director of the employee occupational health service at the Mayo Clinic in Rochester, MN, which has about 20,000 employees who need bloodborne pathogen training.
"It forces [employees] to go slide by slide. They have to be actively involved. There are questions they have to answer and show a level of competence or understanding," he says. "In a lecture-based environment, you could sit in the back row, check off the roster when it goes by, and you're done."
The training is separate from hands-on competency exams that supervisors conduct on individual units, he notes.
Switching off the computers
Hospitals have altered their training methods to conform to OSHA's restrictions on computer-based training.
Central Maine Healthcare, a three-hospital system based in Lewiston, revamped its training as a part of a broader effort to reduce bloodborne pathogen exposures. It updated its devices to newer technologies, emphasized the use of straight needles as opposed to butterfly needles for blood draws when appropriate, and focused on changes in work practices — such as neutral passing zones in the operating room — says Clark Phinney, employee health and workers' compensation manager.
As they realized the existing computer-based training didn't meet the OSHA standard, Phinney and his colleagues considered how they could conform. Who would be available to answer questions for employees taking the class at 2 in the morning on the night shift?
"For us, after we debated it over the course of multiple meetings, a live class really is the immediate best alternative," he says. "It is a live class and everyone is required to take it annually."
Phinney used a template from the American Nurses Association to develop a PowerPoint presentation. He tailored the program for different segments of employees; for example, environmental services and food service workers viewed presentations that focused on the unique hazards in their workplaces. He added site-specific information, such as where and how to report, and other related safety information, such as how to don or doff personal protective equipment.
That meets an important OSHA requirement. According to an OSHA compliance directive, "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 person is accessible for interaction."
"If you're using someone else's program, it's important to make it site-specific," explains Williams. "Some of the hazards at one facility may not be the same at another facility."
It may seem daunting to conduct annual training sessions for more than 2,000 employees and keep track of who missed the training. Central Maine Healthcare is using a "train-the-trainer" approach, with designated clinical staff who have agreed to serve as trainers. Most sessions are held during regularly scheduled staff meetings.
Others are held at 6:30 a.m. or at 6 p.m. to be convenient for either the day or night shifts.
Tailor the medium to your needs
For many hospitals, a well-orchestrated, computer-based system still may be the way to go. Access to an on-call infection control specialist through a hotline number could satisfy the OSHA requirements, Buchta notes.
"I think a little tweaking is all most people need to be compliant with the regulation," he says. "But I think the regulation needs to be looked at to bring it up to reality."
Training has come a long way
The quality of computer-based training has improved significantly, and facilities can embed videos in the presentations to demonstrate techniques, notes Buchta. When employees complete computer-based training at Mayo, human resources automatically receives the information, which provides instant accountability.
"It's easy to run reports of who hasn't completed the training by a certain date," he says.
Meanwhile, Mayo also has targeted specific units with hands-on, one-on-one training to reduce technique-related needlesticks. In some cases, those focused efforts have led to changes in the device selection in favor of newer technology, he says.
It's important to address your training needs with the right kind of training, notes needle safety expert June M. Fisher, MD, director of the TDICT Project at San Francisco General Hospital.
Computer-based training can require employees to be engaged by responding to questions. But it can never substitute the experience of actually demonstrating use of a device. "Each time a new device is used, you have to have hands-on training," she says.
Technology has opened new avenues for health and safety training, but it comes with a caveat: Computer-based modules may not meet the requirements of the bloodborne pathogen standard.You have reached your article limit for the month. Subscribe now to access this article plus other member-only content.
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