As a general rule, registered nurses are viewed to be qualified to conduct training. However, if the registered nurse is not knowledgeable and not comfortable in this role, he or she should request assistance.

Other persons who may provide training include safety/health instructors who have received special training or who have job experience conducting OSHA bloodborne pathogen training. 

The presenter must explain the local school districts policy and procedures and allow employees the opportunity to have their questions answered.

Any employee who is determined to be "at risk" of being exposed to "blood or other material potentially containing bloodborne pathogens in connection with exposure to sharps,” should be offered the vaccine.

“At-risk” status is determined by reviewing job descriptions and categorizing employees. The district risk manager should be involved in working with school administrators to determine who is “at risk” and ensuring the safety of students and staff.

Some districts are offering the vaccines to all employees. However, they are only assuming the financial cost for those employees with the highest risk as determined by job description and risk determination.

The rules do not specify enforcement methods or allow for the assessment of penalties. Department of State Health Services staff will be making random site visits to various governmental units. The focus of these visits will be to provide education and support. It would be important to speak with the school district attorney.

Training should be conducted as outlined in the exposure control plan. For new employees, the training should be comprehensive to include all aspects of exposure control, personal protective equipment and information about the district policy and procedures. Refresher courses should be offered once a year for all returning employees with a review of the district policy and procedures.