Occasionally we are asked questions about OSHA's Regulated Waste Management standard. These questions include:
- Is it permissible to dispose of filled sharps containers that are sealed in the regular trash?
- We have sharps containers for injections in each exam room. We are not aware of any reason we would have a need for a red bag in the exam rooms. Under OSHA, is it mandatory to also have a red bag in each exam room?
Regulated Medical Waste
Under OSHA's Bloodborne Pathogens Standard, Regulated Medical Waste is defined as:
- Liquid or semi-liquid blood or *Other Potentially Infectious Materials (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, 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
Contaminated Medical Waste Management
It's important to note that 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.
Contaminated Sharps Management
OSHA requires that containers for contaminated sharps must be puncture-resistant. The sides and the bottom must be leak-proof. They must be appropriately labeled or color-coded red to warn everyone that the contents are hazardous. Containers for disposable sharps must be closable (that is, have a lid, flap, door, or other means of closing the container), and they must be kept upright to keep the sharps and any liquids from spilling out of the container. The containers must be replaced routinely and not be overfilled, which can increase the risk of needlesticks or cuts. Sharps disposal containers that are reusable must not be opened, emptied, or cleaned manually or in any other manner that would expose workers to the risk of sharps injury. Employers also must ensure that reusable sharps that are contaminated are not stored or processed in a manner that requires workers to reach by hand into the containers where these sharps have been placed.
Disposal Keep State Regulations in Mind
Finally, disposal of all regulated waste must be in accordance with applicable State regulations. Each State has different regulated medical waste regulations and requirements for tracking and record-keeping. Therefore, it is important to check your state requirements.
Conclusion: Application of these Standards in your workplace
- Red Medical Waste Management Bags: If you have a potential for any of the regulated medical waste examples listed above, we would recommend having red bags in those rooms. That's not to say you would need a designated waste container you may consider keeping a red bag in a drawer in the exam rooms for those "just in case" situations. Remember that under OSHA, you can generally dispose of "contaminated" waste (Items that are simply contaminated with small absorbed amounts of blood or OPIM) in regular plastic-lined trash containers.
- Contaminated Sharps: Are defined as "any contaminated object that can penetrate the skin, including but not limited to, needles, scalpels, broken glass, broken capillary tubes, and exposed ends of dental wires. Having sharps containers in each room for injections and other contaminated sharps would be sufficient.
- Disposal of Medical Waste: Sealed sharps containers should not be disposed of in regular trash. Sharps containers must be properly labeled and stored safely and securely until available for disposal. Generally, disposal is with an off-site contracted waste hauler. The disposal of all regulated waste must be in accordance with applicable State regulations. Because of that we recommend verifying your State's medical waste regulations and requirement.
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