OSHA Clarifies ‘Containerization’ for Blood, Body Fluids

OSHA's Bloodborne Pathogens Standard, 29 CFR 1910.1030, has provisions for the protection of employees during the containment, storage, and transport of regulated waste other than contaminated sharps. The standard defines regulated waste as liquid or semi-liquid blood or other potentially infectious material (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.

In a Letter of Interpretation dated June 2, 2009, posted to the agency’s Web site this week, OSHA’s Richard Fairfax, director of the Enforcement Programs Directorate, noted that compliance with the BBP standard is evaluated on a case-by-case basis, and he clarified some of the standard’s provisions.

In response to the questions, “What are the policies for disposal of blood/body fluids and infectious waste? Is blood treated differently than other body fluids?” Fairfax wrote, “In general, regulated wastes, other than contaminated sharps, must be placed in containers which are: (i) Closable; (ii) Constructed to contain all contents and prevent leakage of fluids during handling, storage, transport or shipping; (iii) Labeled or color-coded in accordance with paragraphs (g)(1)(i); (iv) Closed prior to removal to prevent spillage or protrusion of contents during handling, storage, transport, or shipping [29 CFR 1910.1030(d)(4)(iii)(B)(1)(i)-(iv)].

When asked if it was acceptable to throw out items contaminated with blood or body fluids in either septic systems or normal garbage, and, if so, how much blood and body fluids can be present, the director said, “It is the employer's responsibility to determine the existence of regulated waste. This determination is not based on actual volume of blood, but rather on the potential to release blood (e.g., when compacted in the waste container).”

Fairfax did not make a distinction between clinics and hospitals regarding rules for body fluid disposals. He reiterated that the agency approaches each facility setup on a case-by-case basis and that it’s the responsibility of the management at each facility to know the rules of the BBP standard. “Employers in clinics and hospitals must comply with the Bloodborne Pathogens Standard,” he wrote. “Employers must evaluate their individual workplaces and institute measures to eliminate or minimize employee exposure to blood or OPIM based on the unique set of scenarios or tasks in the facility. An exposure control plan is the employer's written program which is required to outline the protective measures taken.”

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