“Do I really have to train physicians in bloodborne pathogens? OSHA doesn’t require them to undergo training like the rest of the practice’s staff, does it?” asked the safety officer from a large group practice.
The answer—that OSHA does not exempt any employee, including a physician, who is exposed to bloodborne pathogens from the initial and annual training requirements of the standard— did not sit well with her. “Oh well, maybe I’ll just have them sign the training sheet and leave it at that.”
It’s a common misunderstanding is that physicians who are owners of a practice are not subject to OSHA requirements. That may have been be true for that old Marcus Welby-type solo practitioner situation, but not for most practices organized as a professional corporation.
Although physicians know that their practices are subject to some form of OSHA regulation, they are not clear on the specifics, especially regarding their own training under the standard, says Kathy Rooker, who advises medical practices on OSHA and CLIA compliance as owner of Columbus Healthcare & Safety Consultants in Canal Winchester, OH.
Rooker will often spend one-on-one time with physicians who own a share of the practice explaining that they, as both employer and employee, are subject to OSHA regulations just as other staff members are.
Understanding the overlap, however, is no guarantee that physicians will jump at the opportunity to attend a bloodborne pathogens training session.
“I don’t need training in bloodborne pathogens; I learned that in medical school” is a common response, says Rooker.
Use exemplars and leverage
Although the requirement for OSHA training is the same for all staff members occupationally exposed to bloodborne pathogens, the approach to training physicians need not be.
With physicians, “you are dealing with very professional people; you have to tell them more than just ‘you have to do it.’ You have to explain why,” says Bruce Cunha, manager of employee health and safety at the Marshfield (WI) Clinic. The approximately 900 physicians at Marshfield all have an ownership stake in the clinic, and all receive OSHA initial and annual training, says Cunha.