OSHA Clarifies Training Requirements for Tattooists

Tattooists and other body piercing artists should receive industry-specific and site-specific training designed to prevent their exposure to bloodborne pathogens and other potentially infectious materials, according to a Letter of Interpretation recently posted to OSHA's Web site.

In answer to the question, "Does OSHA consider generic bloodborne pathogens training to be sufficient for modification practitioners (tattooing and body piercing artists), or should annual training be specific to the unique procedures and practices within the industry (i.e. industry-specific training)?" Richard E. Fairfax, OSHA's director of the agency's Enforcement Programs Directorate, noted that 29 CFR 1910.1030(g)(2) does require that all employees with occupational exposure to blood and OPIM receive initial and annual training on the hazards involved and how to avoid them.

"While the provisions for employee training are performance oriented, with flexibility allowed to tailor the program to, for example, the employee's background and responsibilities, the categories of information listed in paragraph 1910.1030(g)(2)(vii) must be covered, at a minimum," Fairfax wrote. "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, should be included. . . . [I]ndustry-specific information, and, in fact, some site-specific information would be necessary to accomplish this."

Fairfax added that while OSHA does not require the use of its interpretation letters as training materials, their use is encouraged if they help trainers to simplify OSHA policy and the requirements of an applicable standard, which is what they are designed to do. This LOI, dated July 31, 2008, was posted to OSHA's Web site, www.osha.gov, under "What's New" for the date Feb. 28.

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