personnel to protect the confidentiality of sensitive information and mitigate the risk of unauthorized disclosure, tampering, or misuse of records.
6.6 A BODY ART FACILITY must keep all personnel records secure and they must be made available to the regulatory authority upon request. Personnel records must include the full name, job title, exact duties, dates of employment, date of birth, primary residence address, contact information, and a copy of a current government-issued photo ID, to ensure comprehensive documentation of employees. Photo ID must be current and government-issued to ensure that all personnel information is correct. 6.7 A FACILITY must retain all required PERSONNEL training records for 3 years after the training has occurred. It is necessary to maintain training records to verify employees who received the training, understand the scope of training provided, and assess the qualifications of the trainer(s). Maintaining PERSONNEL training records enables a FACILITY to track and demonstrate compliance with training requirements mandated by regulatory authorities or industry standards. 6.8 A FACILITY must maintain PERSONNEL medical records for workers with occupational exposure aligns with regulatory standards outlined in 29 CFR 1910.1030 and requirements set forth by the Department. Facility operators must maintain records for each worker with occupational exposure as required by 29 CFR 1910.1030 and the Department. 1. OSHA’s Bloodborne Pathogens Standard states in section 1910.1030(g)(2)(i) that the “employer shall train each employee with occupational exposure in accordance with the requirements of this section. Such training must be provided at no cost to the employee and during working hours” (OSHA, 2019). Training must be provided at the time of initial assignment to tasks where occupational exposure to blood or OPIM might exist and at least annually thereafter. Section (g)(2) (vii) lists the elements that must be covered in such training. Additional training must be provided when any changes, such as modification of procedures or tasks or the institution of new procedures or tasks, affect the employee’s exposure. A letter of interpretation states that “in this case, the additional training may be limited to addressing the newest information or change in procedure or policy and does not have to cover all the topics included in the initial training” (OSHA, 1997). 2. – 3. OSHA’s Bloodborne Pathogen Standard section 1910.1030(h)(1) requires employers to maintain employee medical records and those records are not to be “disclosed or reported without the employee’s express written consent except to any person within or outside the workplace except as required by this section or as may be required by law” (OSHA, 2019). In the case of contract employees, the PERSONNEL provider and the ESTABLISHMENT OPERATOR have a shared responsibility for assuring that employees are protected from workplace hazards (OSHA, 2011). OSHA standard interpretations state that the ESTABLISHMENT OPERATOR is responsible for “providing site-specific training and personal protective equipment, and would have the primary responsibility regarding the control of potential exposure conditions” and the personnel provider is required to
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