As part of your medical office’s waste management plan, and to maintain compliance with state and federal regulations, you must maintain training records. You are required to keep detailed documents of the training that your employees receive to minimize their exposure to infectious agents. Your documents must describe how your staff was trained to recognize regulated medical waste and to properly manage it.
Additionally, you must specify the type of training that is provided, along with the name of the person who conducts or supervises the training and documents it for each person. Copies of all current employee training certificates should be kept on file — in both the employee’s file and in the waste management file.
Here are the specific training documents that your medical office needs to have on file:
Occupational Health and Safety Administration (OSHA) Training Documents
OSHA’s mission is to ensure worker and workplace safety for all U.S. workplaces, including medical offices. Bloodborne Pathogens is the most frequently referenced standard impacting medical offices, and employee training is a requirement. In fact, OSHA training is mandatory for all employees, including the doctor, nurses, receptionists, and part-time employees.
Bloodborne Pathogens (BBP) Training Documents
You are required to keep current Bloodborne Pathogens (BBP) training certificates for all clinical employees. Training for all employees is mandatory and training for new-hires must be completed within ten days of hire. Regular training should be offered annually.
Waste Handling and Classification Regulations Training Documents
This OSHA course is a necessity for your medical office since state and federal guidelines are stringent and laws can change frequently. Your compliance point-person and anyone in your office with exposure to regulated medical waste should take this course.
Hazard Communication Plan Training Documents
OSHA requires the implementation of a hazard communications program for all employers who have hazardous chemicals in their workplace. The program includes hazardous chemical container labeling, chemical safety data sheets (SDS) for hazardous chemicals, and training for workers. The training covers a review of your HAZCOM program and all protective measures — such as Fire Prevention and Fire Extinguisher Types training, Personal Protective Equipment (PPE) training, and Radiation Orientation.
Department of Transportation (DOT) Training Documents
DOT is another government agency that is concerned about what happens to infectious materials since they are transported on public highways. Training on DOT Hazardous Materials Transportation Regulations (HM-181) should be taken every three years by your compliance point-person and your manifest signer.
Pharmaceutical Waste Training Documents
If you have pharmacy staff, they and your manifest signer should also complete the Pharmaceutical Waste Identification, Segregation and Disposal training.
Health Insurance Portability and Accountability Act (HIPAA) Training Documents
HIPAA is one of the most important regulatory laws that impacts all healthcare settings, designed to protect the healthcare information and privacy of patients. Most medical practices conduct HIPAA training on an annual basis as a best practice. The training is mandatory for any employee who comes into contact with protected health information (PHI) — including clinical and administrative staff.
You must also train and keep documentation for part-time employees and interns. Anyone who is in contact with your patient’s PHI needs training, including your business associates and subcontractors. Documentation of that training should also be kept on file.
Document. Document. Document.
The importance of sound recordkeeping can not be stressed enough. Keeping the proper documentation on file, including up-to-date training logs and training certificates, will help your medical practice maintain compliance and safeguard your workplace and its operations. Make sure you are conducting all of the required training by downloading our compliance training checklists.
Note: We recommend that you keep employee training records for the length of employment, plus five years. Do you have a designated procedure for disposing of documents? We offer secure document destruction services.
