“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.
In addition to keeping Marshfield’s computer-based bloodborne pathogens training interactive as required by OSHA while introducing new content with annual training, Cunha recommends appealing to the safety culture that the organization maintains when dealing with physician OSHA training. That, and making sure you have physicians act as safety champions, he adds.
“Involve physicians directly in developing training. Find a champion on the medical staff, especially one in a leadership position, to help make it knowledge based and as easy as possible to get through while still giving them new information to take away,” says Cunha.
Engage for effective training
When engaging physicians for bloodborne pathogens training, think of yourself as a facilitator, not a lecturer, advises Sarah Alholm, MAS, who provides safety-related healthcare consulting services and training in Asheville, NC, and is the author of OSHA Training Handbook for Healthcare Facilities.
Alholm’s book uses the case study method, one that she feels can especially appeal to initial and annual bloodborne pathogens training because it involves analysis and decision-making, which helps give physicians the sense of directing the content of the sessions, she explains.
Of course, to do that effectively, you have to really know the content, Alholm adds.
Don’t forget that for bloodborne pathogens, OSHA allows you to tailor the training program to the learner’s job duties, background and education. You might not need to spend as much time on the routes, signs, and symptoms of HBV, HCV, and HIV with physicians as you would for other employees. “Touch on the requirements without getting too into the weeds,” says Alholm.
Here are some tips on creating a smooth-running physician bloodborne pathogen training program:
Before the physician training dilemma rears its head again, work on creating a positive pecking order.
• Remind physicians about maintaining a culture of safety and being a safety role model for nonphysical staff.
• Work toward creating a training program that provides knowledge-based content, uses an engaging method of delivery, and allows for one-on-one reinforcement.
• Take time to explain the nuances of being a physician practice owner while at the same time being regarded as an employee subject to OSHA compliance.
• Caution that noncompliance as owner and/or employee on initial and annual training could have financial consequences to the practice in the form of OSHA fines.
Having accomplished that, now focus on getting physician signatures on the training sheet.