As a medical practitioner, you should be aware that there are a number of governing bodies that regulate how you handle and dispose of your office or clinic’s medical waste. The Occupational Safety and Health Administration (OSHA) is one such body.
OSHA’s focus is on worker safety, so their regulations center around the handling of medical waste. Final disposal of medical waste falls under state and local jurisdiction, although the Department of Transport does mandate some transportation elements on medical waste haulers.
There are seven key components of OSHA’s regulations on medical waste, which are outlined in the Bloodborne Pathogens Standard (29 CFR 1910.1030). Let’s look at the key elements of the legislation that impacts medical offices and clinics.
You Must Have a Plan
You should have a written exposure control plan that is reviewed and updated annually. The plan should include all of the positions and technology used to reduce exposure to blood or bodily fluids. Ensure that the plan is readily available to all of the workers at your facility.
Medical practitioners should use Universal Precautions, which are a set of infection control strategies that treat human blood and some bodily fluids as if they were all highly infectious. Medical specialists using this method then act accordingly when coming into contact with blood and fluids.
Using the Universal Precautions method, those coming into contact with these fluids should assume all of them have the potential to be infectious. As a result, they must take the proper precautions when dealing with any of these fluids, even if there is no apparent evidence that they are infectious (hence the words “Universal” and “Precautions”).
Sharps are any medical instrument with points or edges that can puncture skin or a biohazard bin liner. Examples include needles, syringes, scalpels, and even glass.
Sharps that have already been used are considered contaminated medical waste, and are expected to be kept in puncture-resistant sharps boxes. The boxes are to be mounted upright, include a closeable lid, and be leak-proof on the sides and bottom. The boxes are never to be filled more than 3/4 of the way, and usually include a fill line reminding you of that fact.
There are also protocols for where sharps containers are to be kept at your facility. Among other mandates, the Bloodborne Pathogens Standard requires that sharps containers be “easily accessible to personnel.”
OSHA is known to reference the National Institute for Occupational Safety and Health (NIOSH) in medical waste citations. NIOSH has done a number of studies on the main causes of needlestick injuries in medical environments, and has helped shed light on best safety practices. Along with OSHA’s requirement that sharps containers be “easily accessible”, NIOSH has deemed a number of locations in a medical facility significantly unsafe to mount sharps containers.
Unsafe places to keep a sharps container:
● Room corners, backs of doors, under cabinets, under sinks
● In areas where people might sit or lie beneath the container
● Near light switches, room environment controls, or utility access ways
● Where the container is subject to impact and dislodge
● Near pedestrian traffic, moving equipment, gurneys, wheelchairs, or
In addition, NIOSH cautions medical practitioners to only place sharp containers where workers will not have “to make unnecessary movements while holding a sharp and accessing the container.”
OSHA has specific requirements for how medical facilities communicate the nature of the hazardous material inside medical waste containers.
Warning labels are to be “affixed to containers of regulated waste, refrigerators, and freezers containing blood or other potentially infectious material; and other containers used to store, transport or ship blood or other potentially infectious materials”.
The labels are to be fluorescent orange or orange-red with lettering in a contrasting color. The biohazard symbol should be prominent. The labels are to be affixed to the container as close as possible to help prevent their loss or accidental removal.
OSHA mandates that medical staff must receive training on your exposure control plan at the time of hire, and annually thereafter.
The training shall be provided at no cost to the employee, and take place during working hours. Employee participation in the training should be a contingency of employment.
The Bloodborne Pathogen Standard repeatedly states that all medical waste containers should be “constructed to contain all contents and prevent leakage of fluids”. The containers are all required to have closeable lids that are specifically kept closed during transport and removal of the containers. And as noted before, all containers should have the required biohazard labeling.
OSHA requires specific record keeping in relation to medical waste. This falls into two categories: training and incidents.
Employee training records should be as follows:
● The dates of the training sessions
● The contents or a summary of the training sessions
● The names and qualifications of persons conducting the training
● The names and job titles of all persons attending the training sessions
● Training records shall be maintained for 3 years from the date on which
the training occurred
OSHA also requires record keeping in the event an employee becomes exposed to medical waste, like with a needlestick injury for example. OSHA requires employers to “preserve and maintain medical and exposure records for each employees for the duration of employment plus 30 years.”
So these are the key OSHA regulations to be aware of, at least on the federal level. There are also 22 state-level OSHA programs, in addition to other state and local authorities, all of whom you will need to consult for any further regulations you need to comply with.