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[IP] Test strips, a hazard--NOT!



This is from OSHA's Web page.


Q. What does OSHA mean by the term "regulated waste"?
A. The Bloodborne Pathogens Standard uses the term, "regulated waste," to
refer to the following categories of waste which require special handling at
a minimum; (1) liquid or semi-liquid blood or OPIM; (2) items contaminated
with blood or OPIM and which would release these substances in a liquid or
semi-liquid state if compressed; (3) items that are caked with dried blood
or OPIM and are capable of releasing these materials during handling; (4)
contaminated sharps; and (5) pathological and microbiological wastes
containing blood or OPIM.
14

Q. Are feminine hygiene products considered regulated waste?

A. OSHA does not generally consider discarded feminine hygiene products,
used to absorb menstrual flow, to fall within the definition of regulated
waste. The intended function of products such as sanitary napkins is to
absorb and contain blood. The absorbent material of which they are composed
would, under most circumstances, prevent the release of liquid or
semi-liquid blood or the flaking off of dried blood.
OSHA expects these products to be discarded into waste containers which are
properly lined with plastic or wax paper bags. Such bags should protect the
employees from physical contact with the contents.
At the same time, 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). If OSHA determines, on a case-by-case
basis, that sufficient evidence of regulated waste exists, either through
observation, (e.g., a pool of liquid in the bottom of a container, dried
blood flaking off during handling), or based on employee interviews,
citations may be issued.

>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>

October 8, 1992
John J. Sredniwaski
Material Safety Engineer
AIL Systems, Inc.
Commack Rd.
Deer Park, NY 11729
Dear Mr. Sredniwaski:
This is in response to your letter of August 7, regarding the Occupational
Safety and Health Administration (OSHA) regulation 29 CFR 1910.1030,
"Occupational Exposure to Bloodborne Pathogens." Specifically, you requested
a written interpretation on the coverage of feminine hygiene products as
regulated waste.
29 CFR 1910.1030 defines regulated waste as liquid or semi-liquid blood or
other potentially infectious material (OPIM); items contaminated with blood
or OPIM which would release these substances in a liquid or semi-liquid
state if compressed; items that are caked with dried blood or OPIM which are
capable of releasing these materials during handling; contaminated sharps;
and pathological and microbiological wastes containing blood or OPIM.
OSHA does not generally consider discarded feminine hygiene products, used
to absorb menstrual flow, to fall within the definition of regulated waste.
The intended function of products such as sanitary napkins is to absorb and
contain blood; the absorbent material of which they are composed would,
under most circumstances, prevent the release of liquid or semi-liquid blood
or the flaking off of dried blood.
OSHA expects these products to be discarded into waste containers which are
lined in such a way as to prevent contact with the contents. Please note,
however, that it is the employer's responsibility to determine which job
classifications or specific tasks and procedures involve occupational
exposure. For example, the employer must determine whether employees can
come into contact with blood during the normal handling of such products
from initial pick-up through disposal in the outgoing trash. If OSHA
determines, on a case-by-case basis, that sufficient evidence exists of
reasonably anticipated exposure, the employer will be held responsible for
providing the protections of 29 CFR 1910.1030 to the employees with
occupational exposure.
We hope this information is responsive to your concerns. Thank you for your
interest in worker safety and health.
Sincerely,



Ruth McCully, Director
Office of Health Compliance Assistance

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