Part One: What’s Going into that Red Bag?

Red Bag Waste

Reducing Your Medical Waste Through RightClassificationSM – A Three Part Series

Twenty-four years after the Medical Waste Tracking Act prompted the passing of state medical waste regulations, red bags are still being filled with trash. Granted, we seldom see pizza boxes or drink cans in red bags anymore, but we still see trash such as dressings, gauze, gloves, test strips, urine cups, empty medication vials, table and tray covers, device packaging, tubing, pads, and adults diapers. Proper waste segregation (RightClassification℠) is crucial to assure proper containment and disposal of trash, regulated medical waste (RMW), and hazardous waste. Many reasons are given as to why these items end up in red bags, including:

  • “It’s too hard for our clinicians to decide what medical waste is and what it is not!”
  • “Our medical waste company said it has to go in there – or, they never said it shouldn’t!”
  • “We have red bags and no trash cans in rooms – so there is nowhere else to put the trash!”
  • “It’s the patients who put trash in the red bags!”
  • “We train about proper waste segregation, but our employees just don’t do it!”
  • “Our policy says items soaked with ‘body fluids’ must go into a red bag!”

What is the definition of regulated medical waste?

Medical waste becomes regulated when it contains enough blood or other potentially infectious materials (OPIM*) to potentially spread bloodborne pathogens. Therefore if there is not enough contamination with blood OPIM, it is not a regulated medical waste. This definition has been taught to employees for over 20 years as a part of their bloodborne pathogens (BBP) training. Yet when it comes to putting this training into practice, it’s often as if the definition has never been heard. Occupational Safety and Health Administration (OSHA) defines RMW in its BBP Standard as follows:

  • Liquid or semi-liquid blood or OPIM, this includes:
    • Blood in blood tubes, blood or OPIM in suction canisters
  • Contaminated items that would release blood or OPIM in a liquid or semi-liquid state if compressed, this includes:
    • Blood-soaked gauze
  • Items that are caked with dried blood or OPIM and are capable of releasing these materials during handling, this includes:
    • Blood-soaked gauze that has dried and the blood could flake off
    • Bloody gloves or other items that have not absorbed the blood
  • Contaminated sharps, including:
    • Needles, syringes with needles attached, scalpels, dental carpules with blood in them
  • Pathological and microbiological wastes containing blood or OPIM
*Other Potentially Infectious Materials (OPIM) means (1) The following human body fluids: semen, vaginal secretions, cerebrospinal fluid, synovial fluid, pleural fluid, pericardial fluid, peritoneal fluid, amniotic fluid, saliva in dental procedures, any body fluid that is visibly contaminated with blood, and all body fluids in situations where it is difficult or impossible to differentiate between body fluids; (2) Any unfixed human tissue or organ from a human.

Note: Urine and feces, among other body fluids not listed above, are NOT OPIM, and therefore items contaminated with any amount of these body fluids do not carry enough BBP to be considered RMW.

In spite of the definition of RMW, some facilities still believe they must dispose of all items that have been merely “contaminated” with blood or OPIM as RMW, regardless of the amount of contamination. OSHA and state and local regulations do not require this.1, 2 OSHA uses the term “contaminated”, or “potentially contaminated”, to refer to anything that has or could have any amount of blood or OPIM on it. “Contaminated” is NOT necessarily the same as “regulated”. Items that are simply contaminated with small absorbed amounts of blood or OPIM may be placed in a regular plastic-lined trash container.

What is an inspector looking for?

In order for inspectors to interpret the regulations as intended, OSHA provides compliance directives for its standards. The current federal compliance directive for the BBP Standard is CPL 02-02-069.

Taken directly from CPL 02-02-0693 “The compliance officer should not use the actual volume of blood to determine whether or not a particular material is to be considered regulated waste, since 10 ml of blood on a disposable bed sheet would appear as a spot (not regulated waste) while the same amount of blood on a cotton ball would likely cause saturation and dripping (regulated waste). Instead, the compliance officer should consider the potential for generation of bulk blood (i.e. through dripping or flaking off of material that may contain either blood or OPIM). Note: employees must handle items contaminated with ANY amount of blood or OPIM using Universal Precautions; the definition of regulated medical waste refers to how much blood or OPIM that item contains in order to decide if it should be discarded in the regular plastic-lined trash container, or the red-bag lined regulated medical waste container.”

Part 2 of this series will talk about state disposal regulations and how to properly segregate, contain, and dispose of RMW.

1) OSHA Bloodborne Pathogens Standard
2) State Medical Waste Regulatory Map
3) CPL 02-02-0693 – Enforcement Procedures for the Occupational Exposure to Bloodborne Pathogens

Jan Harris

Jan Harris

Director of Environmental, Health and Safety at Sharps Compliance
Jan Harris holds a masters degree in Occupational Health and Safety Management and is an authorized OSHA outreach trainer. She has worked as a consultant focusing on OSHA and medical waste compliance since 1990, and for Sharps Compliance since 1999.
Jan Harris

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Author: Jan Harris

Jan Harris holds a masters degree in Occupational Health and Safety Management and is an authorized OSHA outreach trainer. She has worked as a consultant focusing on OSHA and medical waste compliance since 1990, and for Sharps Compliance since 1999.