Every year, medical facilities create 3.2 million tons of hazardous waste, which is categorized into four areas: solid, chemical, radioactive, and infectious (Fremgen, 165). The latter, infectious, means that the waste material “as the potential to carry disease” and more than 320,000 tons of the hazardous waste created each year is considered infectious (Fremgen, 166). OSHA defines (other potentially) infectious materials, or OPIM, as being human bodily fluids; unfixed human tissues or organs; fluids, tissues or organs from an HBV or HIV infected experimental animal; and HBV or HIV carrying cultures (OSHA). This can also include contaminated inanimate objects and there are precautionary methods for handling encounters with these materials.
During surgical procedures, “all human blood and certain human bodily fluids are treated as if known to be infectious” and personnel should wear personal protective equipment to reduce the risk of infections (Henshaw: Letter to Nickles). When potentially infectious materials make contact with laundry or re-usable protective textiles, it is the responsibility of the employer to have the items placed into a color-coded leak-resistant bag or container to be washed with detergent in hot water that is greater than 160° Fahrenheit for at least 25 minutes, or with proper chemicals for textiles that cannot be washed at that temperature (CDC). It is not acceptable by OSHA’s standards for textiles to be washed at home by the employee (Fairfax: Letter to Kaye). For re-usable equipment, such as instruments, the items must be pre-cleaned to remove all organic material, and then sterilized with either flash steaming which is at 270° Fahrenheit minimum for at least three minutes, or through a chemically approved process (Garner, et al).
Once an employee has handled, even with protection, any infectious material, OSHA requires that they must wash their hands, per 29 Code of Federal Regulations (CFR) 1910.1030 (OSHA). The regulation states that employees will wash their hands as soon as feasible after removing their protective gear with soap and running water, as well as washing any other exposed skin. OSHA determined that using alcohol based rubs or hand sanitizers are not a suitable alternative for hand-washing (Fairfax: Letter to Zalen).
Even in the process of drawing blood for testing or injections done by needle, there is the risk of infectious waste being created. These items, called sharps, include any object that can penetrate the skin, such as needles, scalpels, wires, or broken glass (OSHA). Guidelines are in place to reduce the risks of being punctured by such items. One of these guidelines is the prohibition of recapping a needle. Recapping occurs when the safety cap of a needle is placed back over the needle and the risk is that when done using two hands, the employee may accidentally miss and thereby puncture their flesh with the used needle. If there is no alternative, such as a multi-use pen-style needle that comes in no other design, then it may be recapped, but only while using the one hand method (Fairfax: Letter to Toriello). Otherwise, sharps must be disposed of, as mandated through the Needlestick Prevention and Safety Act, into durable containers that are leak-proof and puncture-resistant (US DHHS, 4). The containers should be readily accessible, plentiful, and visible by employees who may need to dispose of sharps; and they should enable an employee to note the fill level of the container without endangerment to the employee (US DHHS, 4). These containers must also be designed in a manner that prevents tampering or removal of objects through tampering (US DHHS, 15).
As medical professionals, we have an obligation, both legally and ethically, to protect the public from unnecessary harm resulting from the hazardous medical waste (Fremgen, 166). By following federal standards established by CDC, DHHS, and OSHA, we can fulfill that obligation and also prevent the needless contamination of ourselves in the process. The precautionary methods of handling infectious materials and objects contaminated by infectious materials are simple and easily implemented; and they are the law.
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Fairfax, Richard E. “03/31/2003 – Acceptable Use of Antiseptic-hand Cleansers for Bloodborne Pathogen Decontamination and as an Appropriate Handwashing Practice.” Letter to Janice Zalen. 31 Mar. 2003. Occupational Safety and Health Administration – Home. Web. 21 Sept. 2010. <http://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=INTERPRETATIONS&p_id=24389>.
Fairfax, Richard. “12/09/2004 – Needle Removal Procedures for Situations Where Other Methods of Disposal Are Infeasible or Required by a Specific Procedure.” Letter to Kathy Toriello. 9 Dec. 2004. Occupational Safety and Health Administration – Home. Web. 22 Sept. 2010. <http://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=INTERPRETATIONS&p_id=25092>.
Fairfax, Richard E. “02/27/2009 – Compliance with the OSHA Bloodborne Pathogens Standard, 29 CFR 1910.1030.” Letter to Joseph Kaye. 27 Feb. 2009. Occupational Safety and Health Administration – Home. Web. 21 Sept. 2010. <http://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=INTERPRETATIONS&p_id=27008>.
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