Every OSHA checklist for a medical office lists the same three items: exposure control plan, hazard communication program, sharps injury log. Treated as one bundle, when they are governed by two different standards that ask two different questions about the same roster. 1910.1030(b) asks who has reasonably anticipated contact with blood. 1910.1200(h) asks, separately, who handles hazardous chemicals in their own work area. A physician can be on the first list and off the second.
The frequencies do not match either. Bloodborne pathogens training runs on a fixed annual clock. Hazard communication training runs on initial assignment and on a new hazard arriving -- there is no annual date in the federal standard at all. A checklist that assigns one due date to "safety training" is wrong for whichever program it didn't write the rule for. Neither determination is touched by Part 1904's separate recordkeeping exemption, which most physician and dental offices already qualify for regardless of size.
Foothill Family Medicine, a fictional single-location practice with 14 employees, ran both determinations on its roster. Eight employees, its two physicians, five clinical staff and one janitorial role, have bloodborne pathogens exposure. Six, its clinical staff and janitorial role, but not its physicians, have hazard communication exposure. Its NAICS code sits on the Part 1904 exemption list, so it owes neither the OSHA 300 log nor the sharps injury log tied to it, absent a written request. All eight still get the full bloodborne pathogens program regardless.
OSHA Workplace Safety Checklist Template