I am the EH&S person for a chemical lab that occasionally tests drug products that are classified as biosafety level 1. We do not work with blood or any other body fluids. Recently the Pennsylvania Environmental quality board passed a final rule to amend the Regulated Medical and Chemotherapeutic Waste regulation (Chapter 284) so that BSL-1 waste is no longer classified as either infectious waste nor regulated medical waste for waste purposes.
I give initial bloodborne pathogen training to all new employees to cover this BSL-1 testing but am I also required to give annual training to everyone in bloodborne pathogens if the lab only tests BSL1 drug products?
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