General Medical Waste Management Under OSHA’s Bloodborne Pathogens Standard

Bloodborne Pathogen

The Occupational Safety and Health Administration’s (OSHA) Bloodborne Pathogens (BBP) Standard, 29 CFR 1910.1030, was first issued in 1991 to protect employees from occupational hazards posed by exposure to microorganisms present in human blood that can cause disease in humans. The Standard defines “regulated waste” as follows:

  • liquid or semi-liquid blood or other potentially infectious materials (OPIM)*,
  • contaminated items that would release blood or OPIM in a liquid or semi-liquid state if compressed,
  • items that are caked with dried blood or OPIM and are capable of releasing these materials during handling,
  • contaminated sharps, and
  • pathological and microbiological wastes containing blood or OPIM.

The Standard further defines “contaminated” as “the presence or the reasonably anticipated presence of blood or OPIM on an item or surface” and not necessarily the confirmed presence of pathogens. Because of this, OSHA promotes practicing universal precautions as established by the Centers for Disease Control, which maintain that all blood or body fluids are potentially capable of transmitting disease. Employers are required to assess employee exposure to such contaminants using an exposure determination based on the following:

  • Which job classifications entail specific duties and procedures with a reasonable expectation for skin, eye, mucous membrane, or parenteral exposure to blood and OPIM
  • The identification of which waste streams in their workplace have the potential to release blood or OPIM

Over the years, OSHA has issued numerous citations and fines for violations against the proper handling and containerization of regulated medical waste, such as pooled body fluid at the bottom of a container. Any receptacle used for solid or liquid medical waste capable of emitting odors or attracting vermin must meet the following requirements:

  • Closable with a solid tight-fitting cover (must be closed between use and upon removal from use)
  • Constructed to contain all contents and prevent leakage of fluids during handling, storage, transport, or shipping
  • Biohazard label with symbol must be securely affixed, or container may be red/red-orange color-coded

Such receptacles, typically red plastic bags, must be sealed before removal from use to prevent spillage or protrusion of contents during handling, storage, transport, or shipping. If the exterior of the bag becomes contaminated, the employer must provide secondary containment capable of preventing spillage during handling and transport. The 20-Gallon Medical Professional Sharps Recovery System is a USPS-authorized medical waste mailback system for the easy collection, transport, and destruction of regulated medical waste.

OSHA also expects all soiled wastes which aren’t regulated in the workplace, such as gauze or PPE not grossly contaminated with blood or OPIM, to be discarded in containers properly lined with plastic or wax paper bags to protect employees from physical contact with the contents. All waste should be removed at a frequency to maintain the workplace in a sanitary condition.

Though the requirements set forth by OSHA’s BBP Standard are generally consistent with most states’ regulations concerning the handling of medical waste, often states impose even stricter requirements on waste generators. Compliant management of medical waste is not limited to just OSHA’s oversight, but other federal entities such as the Department of Transportation and the Environmental Protection Agency, among others. Let Sharps Compliance’s Regulatory Compliance Team assist you in navigating your state’s regulations and guidelines with our personalized service and tested disposal solutions.

*OPIM:  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.

Kathryn Kane-Neilson

Author: Kathryn Kane-Neilson

Kathryn earned her Bachelor of Science with a concentration in cellular pathology from the University of Texas and high-complexity testing certification by the ASCP. Kathryn has been published in the journal Cancer Cytopathology and has seven years’ experience in clinical laboratory as well as experience developing comprehensive training on biohazardous waste management in clinical and research settings.