Training must be done for all affected employees and must be repeated on an annual basis. For all new employees, training must be done at the time of hire. Training must be conducted by a knowledgeable trainer and must provide an opportunity for workers to ask questions. A video tape is not enough. All other methods of compliance must be in place 120 days after the standard goes into effect.
Engineering controls are the method of choice to prevent or eliminate exposure.
OSHA has instructed compliance officers that employers who do not use engineering controls to minimize or eliminate exposure can be cited. We interpret that to mean that the employer must have a compelling reason beyond cost why proven engineering controls such as safe needle devices are not being used. Protective equipment such as gloves, masks, face shields and goggles that fit and are accessible. A post-exposure medical evaluation program after an exposure incident. There are several ways that unions might insure that their members are being protected.