FAQ: Are MDs Exempt from OSHA Training Standards?

FAQ: Are MDs Exempt from OSHA Training Standards?

Jill James

Jill James

Chief Safety Officer

Jill James brings an unrivaled perspective on risk, regulation and liability. With 14 years of experience as a Senior OSHA Safety Investigator with the State of Minnesota, and nearly a decade in the private sector as a safety program manager, Jill is a passionate advocate for training ROI.

In conversation with customers, this question comes up often enough to be addressed, so I’m going into more detail here with a full explanation:

"Are MDs and PhDs exempt from OSHA federal safety training standards?"  

No.  

Medical doctors are not exempt from OSHA laws or training requirements. The same is true for PhDs in any workplace settings.

If there is an employer/employee relationship between physicians and the employers, those personnel need training just like the rest of the employed workforce.

The confusion here frequently stems from a lack of consideration for the breadth of OSHA federal safety training standards, which are numerous and wide-ranging in scope.

MDs for example, may be well aware of typical training topics such as bloodborne pathogens (BBP), or tuberculosis, as those hazards are directly related to the scope of a diverse medical practice. Yet these personnel feel that there is little more to learn from safety training on such topics, because of a close familiarity with the subject matter, and assume an exemption. Time and again, I’ve heard this argument from various employees in multiple workplace settings having earned either a MD or PhD.

And that’s to say nothing of other OSHA training standards that may be applicable to healthcare settings or other workplace settings employing highly educated people.

As safety professionals, of course we can argue that the scope of knowledge for MD/PhD types may not include the specifics of an OSHA standard or other regulatory standard. For MD’s this could be knowledge of safe needle devices currently on the market and how they are used. Or what constitutes a ‘full’ sharps or biohazard container, and what can and cannot be placed in such a receptacle by way of regulated waste category. Or, another example is knowing the frequency with which healthcare professionals are required to have Mantoux skin tests based on the epidemiology of disease in their county.

And, there is so much more. 

MDs and PhDs have other hazard exposures too, such as electrical, ergonomic, respiratory, laser, radiological and on and on and...MDs and PhDs or other highly educated professionals simply aren’t exempt and do have workplace exposure to recognized hazards common or otherwise and therefore need training. 

Now, for employers who specifically work with MDs and PhDs who are contracted as independents, and feel they are exempt from safety training, you can make such training a condition of the agreement. At Vivid, we have one healthcare customer who does just that. Why? Because of a little policy OSHA has called the Multi-Employer Worksite Policy, which spells out your responsibility as the host employer. 

If that is your situation, here is the policy.