| FAQ - Waste - Archived Through 2012
We have been following the CDC Guidelines for Infection Control in Dental Healthcare Settings regarding regulated waste vs. non-regulated waste. Gauze, cotton rolls, gloves, etc. that were used during the patient visit, but are not saturated or soaked with blood or saliva, are being discarded in regular waste. However, during a recent visit by our University's Environmental Health and Radiation Safety Office, we were instructed to dispose of everything that has been in contact with the patient during the course of treatment in the red containers. They sighted the OSHA definition of regulated waste which can be interpreted both ways. Please clarify. By following the CDC guidelines, are we non-compliant with the OSHA regulations?
Because state and local regulations/laws vary among states, OSAP is not in a position to determine whether or not your facility would be non-compliant with the OSHA Standards.
While we can provide you with general information that may assist you in understanding your University's requirement, the University's Environmental Health and Radiation Safety Officer is in a better position to explain all applicable regulations/laws in your state and the rationale for requiring all patient contaminated waste to be disposed of in red containers. The Safety Officer may also contact your state OSHA office and county public health department for clarification of local regulations.
The Centers for Disease Control and Prevention (CDC) guidelines are superseded by federal, state, and local regulations/laws. In addition, states with state operated OSHA plans must enforce the Federal Standards, however, state plans may have stricter interpretations of the Standards. The federal, state, and local Environmental Protection Agency (EPA) also regulates waste disposal, including waste generated by dental facilities. Although differences among federal agencies concerning the definition of infectious medical waste have narrowed, these definitions may be superseded (additional soiled items included) by some states and local jurisdictions.
OSHA regulates waste while it remains inside the facility. After regulated waste leaves the facility, the transport and ultimate disposal of hazardous waste is regulated by the EPA.
OSHA defines regulated waste as: Regulated Waste means liquid or semi-liquid blood or other potentially infectious materials; contaminated items that would release blood or other potentially infectious materials in a liquid or semi-liquid state if compressed; items that are caked with dried blood or other potentially infectious materials and are capable of releasing these materials during handling; contaminated sharps; and pathological and microbiological wastes containing blood or other potentially infectious materials. (1)
The authors of OSAP's Interact Infection Control and Safety Training System state: waste that has had contact with blood or other body secretions may be considered contaminated waste. Contaminated waste, in most states, is eventually disposed of as general waste. Some states, however, may consider and define contaminated waste as regulated waste. (2)
According to the authors of Infection Control & Management of Hazardous Materials for the Dental Team, the CDC guidelines make two recommendations for general medical waste. First, a medical waste management program for the practice needs to be developed. This written program must follow federal, state, and local regulations. Second, dental practices also need to ensure that all personnel who handle and dispose of potentially infective waste are trained in appropriate methods and that they are informed of the possible safety and health hazards. (3)
1) OSHA's Bloodborne Pathogens Standard 29 CFR 1910.1030
OSHA Bloodborne Pathogens Standard 29 CFR 1910.1030
2) OSAP's Interact Infection Control and Safety Training System. By Eklund and Bednarsh. Copyright 1999.
3) Infection Control & Management of Hazardous Materials for the Dental Team. Third
Edition. By Miller and Palenik. Elsevier Mosby Publishers. Copyright 2005.