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J Oncol Pract. 2005 November; 1(4): 175–176.
PMCID: PMC2794563

Staff Training: How to Meet OSHA Requirements

Oncology practices have unique workplace safety hazards, such as exposure to cytotoxic drugs. However, as for any employer, the occupational safety training program must meet the requirements of the U.S. Occupational Safety and Health Administration (OSHA).

Most OSHA standards have training requirements, said Dionne Williams, a senior industrial hygienist in OSHA's Office of Health Enforcement. Employee training is required by OSHA's Occupational Safety and Health Standards, 29 CFR Part 1910, for multiple sections that are relevant to a medical office.1 They include:

  • Bloodborne pathogens (1030)
  • Hazard communication (1200)
  • Personal protective equipment (PPE; 132-134) and first aid (151)
  • Exit routes (35-39)
  • Emergency action and fire prevention plans (38 and 39, respectively)
  • Electrical hazards (332)

When there is no specific standard, OSHA requires employee training under the General Duty Clause in Section 5(a)(1) of the Occupational Safety and Health Act of 1970. This clause mandates that employers provide a safe work environment for employees. Examples of training topics that would fall under this clause are control of tuberculosis transmission and ergonomic safety, Williams said.

Training Requirements

Employers should refer to OSHA's Web site ( for specific training requirements of OSHA standards. For instance, the bloodborne pathogens standard requires employers to inform employees about the dangers of these pathogens, preventive practices and postexposure procedures.2

Under the hazard communication standard, 29 CFR 1910.1200(h)(1), “employers should provide employees with effective information and training on hazardous chemicals in their work area” and the requirements of this standard. Other information should include use of labels and material safety data sheets, location and details of the written hazard communication program, health hazards of chemicals in the work area and protection methods, including PPE.

Training in PPE should explain when it is needed; how to appropriately select, maintain and use PPE; length of useful life; and proper disposal [29 CFR 1910.132(f)].

Ergonomic training provides an overview of the potential risks, causes and symptoms of back injury, and other musculoskeletal injuries. For OSHA compliance, the trainer should identify methods of controlling ergonomic stressors through engineering, administrative and work practice controls.3 Employees also must learn proper lifting techniques and the procedures for reporting potential ergonomic problems.3

OSHA expects employers to document in writing that they met training requirements for each employee, Williams said. Standards such as PPE specify that the documentation should contain the name of the employee and the date and subject of training [29 CFR 1910.132(f)(4)].

Training Frequency

Training must be provided at the time of an employee's initial assignment. Some OSHA standards, such as bloodborne pathogens and respiratory protection, require annual training. Training about ergonomic hazards and controls should be continual.3 Other standards, such as hazard communication and PPE, need refresher training in the following situations, according to Williams:

  • Changes in the workplace or job duties create a new hazard or make previous training obsolete
  • After a hazard exposure incident
  • OSHA changes a standard or requires something additional

Employers also should retrain in PPE if they believe the employee lacks the needed understanding and skills to safely perform the work [29 CFR 1910.132(f)(3)(iii)].

Resources on Safety Training

The best person to provide the training, according to training experts, is an employee or manager who is experienced and informed in safety regulations. If a trainer is not available on staff, other options include consultants and training videos. Another possible source of training information is your professional liability insurer. Here are other resources:

Improve Your Training Program

A chemotherapy spill occurred in July at the Dartmouth-Hitchcock Medical Center in Lebanon, New Hampshire, when a patient's intravenous line dislodged accidentally. Nurses on the oncology unit did not panic and kept both the patient and themselves safe.

Everyone knew what to do because they had undergone hands-on safety training a month earlier in which they simulated such an accident, said Megan Rezendes, RN, MSN, AOCN, a clinical nurse specialist at Dartmouth-Hitchcock's Norris Cotton Cancer Center. She credited her employees' ability to recall all the information they had learned in training to her innovative method of using a mannequin to act out realistic danger scenarios.

“It's hard to pull away employees who love their work to do mandatory training,” Rezendes said. “The big thing is to make it fun and keep people engaged.”

Improving your employee training program can be as simple as varying your training methods or designing an enjoyable way to evaluate trainees' retention of information.

La Verne, California-headquartered Wilshire Oncology Medical Group uses crossword puzzles to quiz new employees on material in their printed training modules.

“We wanted to make it more interesting and have something in writing to show [that] we complied with OSHA requirements,” said Raja Vakil, clinical research coordinator at the six-site oncology practice.

As documentation, Wilshire Oncology managers keep an employee's completed crossword puzzles in that employee's records, Vakil said. All trainees answer the puzzle questions correctly, showing that “everyone is up to speed on training,” he said.

Another indication of the effectiveness of Wilshire's training program is its low rate of hazard exposure incidents. Vakil said the practice, which has nearly 100 employees, has had no major incidents since they began using the modules in 2002.

The five training modules were created using information from OSHA and other resources. They deal with chemical hazards, bloodborne pathogens, fire safety, emergency preparedness, and safe work practices.

What works for Wilshire Oncology may not work for other practices, however. “If a small practice trains only one employee a year, it doesn't make sense to develop training modules and exams,” Vakil said. “They'd be better off [training] one on one.”

Likewise, a large practice that trains 10 employees a month would likely find training classes to be most efficient.

“It's necessary to customize training for your staff and your practice,” he said.


1. Occupational Safety and Health Administration (OSHA): A guide to compliance with OSHA standards, Medical and dental offices, Publication 3187-09R, Washington, D.C. U.S. Department of Labor, 2003
2. OSHA: Bloodborne pathogens, OSHA fact sheet, Washington, D.C. U.S. Department of Labor, 2002
3. OSHA: Ergonomics, HealthCare Wide Hazards Module,, Washington, D.C. U.S. Dept of Labor, Hospital eTool

Articles from Journal of Oncology Practice are provided here courtesy of American Society of Clinical Oncology