Labor Law Guy

Modification Practitioners (!) Come Under the OSHA Knife

Posted in Federal Labor Law, Random Musings by laborlawguy on March 4, 2009

I was grateful to learn today that the Occupational Safety and Health Administration (OSHA) has clarified its position on modification practitioners.

Say who?

It’s a fancy term for tattooists and body-piercing artists (I’m not sure artists applies, but whatever), and OSHA has stepped in with a Letter of Interpretation (LOI) about training requirements for said manipulation practitioners.

In answer to the question, “Does OSHA consider generic bloodborne pathogens training to be sufficient for modification practitioners (tattooing and body piercing artists), or should annual training be specific to the unique procedures and practices within the industry (i.e., industry-specific training)?” Richard E. Fairfax, OSHA’s director of the agency’s Enforcement Programs Directorate, noted that 29 CFR 1910.1030(g)(2) does require that all employees with occupational exposure to blood and OPIM* receive initial and annual training on the hazards involved and how to avoid them.

“While the provisions for employee training are performance oriented, with flexibility allowed to tailor the program to, for example, the employee’s background and responsibilities, the categories of information listed in paragraph 1910.1030(g)(2)(vii) must be covered, at a minimum.”

That’s probably more than any of us would care to know about OSHA and tattoos and body piercings, but if you’re curious, you can go to to the What’s New section for Feb. 28, 2009.

* Other Potentially Infectious Material, and yes, I had to look it up.

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