Monday, August 16, 2010

Very interesting outcome on BBP topic - liquid solidifers

My orignial question;
BBP question. Liquid solidifier comes in a powder or liquid. You then can pour into say a disposable bowl of water used on a client for cleaning the skin on face or a tattoo rinse cup used to rinse tubes of color when tattooing. Any hoo used for long time now. I sprinkle into cup or bowl then set and put in trash as know longer a liquid. It also cannot be re-hydrated. For me, I then wrap all disposable used during tattooing in plastic and toss.

Some one is telling would still be BBP and have to go in Bio bag. I disagree as no longer a liquid and can not get a drop of blood out of it??????????????? Especially when most sop up liquid with a paper towel and toss in trash. That is still liquid and can be re-hydrated???

Thoughts please. Jane


Generally, a substance is considered regualated waste if it is liquid, compressible, etc. HOWEVER, dried or caked blood or other OPIM that are capable of releasing blood may also be considered regulated waste. Consider the reactivatio of a dried blood sample, for example. Here's a letter of interpretation: Joe T

June 2, 2009

Teika Tanksley
2289 Rankin Ave
Columbus, OH 43211-2376

Dear Ms. Tanksley:

Thank you for your letter to the Occupational Safety and Health Administration (OSHA). Your letter was routed to another office before being forwarded to the Directorate of Enforcement Programs in OSHA's National Office. You had several specific questions regarding disposal of blood and other infectious waste. This letter constitutes OSHA's interpretation only of the requirements discussed and may not be applicable to any question(s) or scenarios not delineated within your original correspondence. We apologize for any delay in responding to your inquiry. For clarification, your questions have been listed below followed by OSHA's responses.

Question 1: What are the policies for disposal of blood/body fluids and infectious waste? Is blood treated differently than other body fluids?

Reply 1: The final disposal of all regulated waste must be in accordance with applicable regulations of the United States, States and Territories, and political subdivisions of States and Territories [29 CFR 1910.1030(d)(4)(iii)(C)].

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 [29 CFR 1910.1030(d)(4)(iii)(B)]. The bloodborne pathogens 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 [29 CFR 1910.1030(b)].

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)].

Question 2: Is it acceptable to dispose of items that have blood or body fluids present in either septic systems or normal garbage? If so, how much blood and body fluids can be present?

Reply 2: Please see our reply to question #1 for OSHA's definition and requirements for containerization of regulated waste as well as information on the requirements for final disposal of regulated waste. 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).

Question 3: What are the repercussions when addressing facilities where violations have been found on improper disposal, and what are the common disposal-related violations found during OSHA inspections
Reply 3: When OSHA conducts an inspection addressing regulated waste concerns, compliance with the Bloodborne Pathogens Standard is evaluated on a case-by-case basis. If OSHA determines that sufficient evidence exists that the standard has been violated, a citation carrying monetary penalties may be issued to the employer. Over the past 5 years, OSHA has issued numerous violations for improper containerization of regulated waste [i.e., violations of section 1910.1030(d)(4)(iii)(B)(1) of the Bloodborne Pathogens Standard].

Question 4: Are there different guidelines for body fluid disposals with clinics versus hospitals?

Reply 4: Employers in clinics and hospitals must comply with the Bloodborne Pathogens Standard. 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.

Thank you for your interest in occupational safety and health. We hope you find this information helpful. OSHA requirements are set by statute, standards, and regulations. Our interpretation letters explain these requirements and how they apply to particular circumstances, but they cannot create additional employer obligations. This letter constitutes OSHA's interpretation of the requirements discussed. Note that our enforcement guidance may be affected by changes to OSHA rules. Also, from time to time we update our guidance in response to new information. To keep apprised of such developments, you can consult OSHA's website at If you have any further questions, please feel free to contact the Office of Health Enforcement at 202-693-2190.


Richard E. Fairfax, Director

Directorate of Enforcement Programs

Joe Teeples

We're Into Safety
1015 South 233rd Place
Des Moines, WA 98198

1 comment:

  1. Hi Jane,

    This is the phrase in the regulation that you've got to be careful about when using solidifiers. Don't get me wrong, I think it's a great idea and have always been a proponent of this kind of stuff, but the phrase " items that are caked with dried blood or OPIM and are capable of releasing these materials during handling" indicates to me that if the blood can be released during handling, it should be considered hazardous waste. Think of the downstream trash collection.. Think of the worst case scenari.. A cllient has HIV/HBV and the blood is contaminated. This is lethal. Now we clean it up with a solidifier. Would you touch it with your bare hands? Because the trash collectors will....

    That's why OSHA uses the Universal Precaution so much. Consider it all to be contaminated and your mind set changes.

    It's worth a letter to the manufacturer of the solidifier to see if they are willing to take a stand on this one. If they come back and say that there is no potential for release or contamination (I think they're legal department won't let them say this...) then we can just toss it in the trash.

    Otherwise... treat it as hazardous waste... Tag it and bag it!