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Workplace safety concerns in the restroom

Updated on March 21, 2016

The OSHA standard “Regulated Waste (d)(4)(iii)”:

This paragraph requires regulated waste to be properly contained and disposed of, so as not to become a source of transmission of disease to employees. To eliminate the implication that OSHA has determined the "infectivity" of certain medical wastes, the bloodborne pathogens standard uses the term "regulated waste" to refer to the following categories of waste which require special handling, at a minimum: liquid or semi-liquid blood or OPIM; items contaminated with blood or OPIM and which would release these substances 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; pathological and microbiological wastes containing blood or OPIM.

OSHA crafted several letters of interpretation on this topic in the early 1990s (04/17/1992, 05/28/1992, 06/01/1992, 06/04/1992, 06/25/1992, 09/01/1992, 10/08/1992, 02/02/1993) which all stated that:

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.

Further guidance stated:

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.

Potential for occupational exposure.

Current State: Change in Feminine and Personal Hygiene Products & Disposal

At the time, the guidance provided by OSHA was likely accurate and appropriate. Over time however, feminine hygiene products have changed. Its not just super absorbent sanitary napkins any longer. Manufacturers have created a plethora of products for feminine hygiene and they have been under pressure to reduce absorbency of tampons and the number of additives leaving the tampon ingredients to consist of mostly cotton and rayon; the materials used in regular wearable garments, like tee shirts. There are many reasons for this change over time, including risk of toxic shock syndrome (TSS) for those leaving products inside the body for extended periods of time. This has resulted in decreased effectiveness of leak barriers and removal of chemical and physical additives that hold liquid in these products when compressed. In addition, tampon applicators are usually plastic or cardboard and are not absorbent at all and become soiled with bodily fluids when used. These items should be carefully discarded.

In addition to these manufacturing changes over time for feminine hygiene products, similar issues are occurring with the use of incontinence products that are used by both men and women. Incontinence products are made to be slimmer and more discreet. As such, they do not have the absorbency they did many years ago creating the need for more frequent changing and potential exposures for facility staff that are emptying disposal bins, especially when the bins are neither lined, nor are individual product disposal bags provided. Many restrooms do not provide disposal options at all for used incontinence items which is a growing concern.

Some restrooms currently have individual product wax paper liners available that are no longer effective in capturing the waste in newer designed personal hygiene products. In the 1990's, when OSHA provided its original guidance, feminine hygiene products including sanitary napkins were large enough to roll up and place in a wax paper liner bag snugly with little opportunity for the product to fall out of the bag. Due to the fact that items are thinner, smaller, and more compact, the items often fall between the liner and the bin resulting in the employee having to retrieve the product at the bottom of the bin and wipe it clean.

More women than ever are working, traveling and going to school, they cannot stay home, sit out or take breaks for menstruation. In addition, the number of people with incontinence is growing and with the availability of so many great incontinence care products, they still carry on with their daily lives and activities. However, they need and have a right to access clean, sanitary disposal options in the restrooms and providing it to them not only protects them but everyone else who comes into contact with these items.

Direct Occupational Exposures

Due to the fact that these products are now less absorbent and more frequently discarded, many job classifications of workers are potentially exposed to blood, body fluids, and OPIM during the normal course of their job duties, including environmental services, housekeeping, janitorial, facilities management, and operations. These employees can be employed directly by workplaces or as contract services. Typically, because these duties are performed during off-hours, there may be less oversight, inability to report an exposure as soon as possible, and in busy public locations such as airports or in turning over guest rooms in lodging facilities like hotels, increased pressure to perform tasks quickly.

In addition, many lodging facilities like hotels, motels, inns, and resorts are moving toward liner-less waste baskets in guests’ rooms. Often there is a single piece of paper at the bottom of the trash can and employees have to empty and clean out these waste bins with used and discarded personal hygiene products, including condoms, feminine hygiene products, incontinence products, and wipes.

In the compliance directive, OSHA states the following with regard to “housekeeping” in “worksites which have a reasonable possibility of becoming contaminated with blood or OPIM” and can be applicable to the workplaces described above:

Paragraph (d)(4)(ii)(C) requires both the inspection and decontamination, on a regularly scheduled basis, of cans, bins, pails, and so forth which are intended for reuse. Since these containers may be used in a manner which presents the potential for their becoming contaminated with blood or OPIM, they must be cleaned immediately or as soon as feasible upon visible contamination. For example, a reusable metal trash can could have been lined with a disposable plastic regulated waste bag which leaks and contaminates the can. In addition, regular decontamination will prevent the can from leaking, spilling, or contaminating the outside of successive bags.

Due to the changing manufacturing, availability and design of these products described above and because many reusable trash cans / bins are not lined with disposable plastic bags / liners nor available individual product disposal bags, occupational exposures due occur. Additionally, most housekeeping and facilities staff are not provided personal protective equipment (PPE) including gloves nor are they equipped with disposal bags that are labeled or color-coded for use with these specific products, and as such exposures to blood, body fluids, and OPIM can occur during the normal course of their job duties. As such, some guest rooms in lodging facilities can have exposures similar to those addressed in the compliance directive for healthcare facilities.

Indirect, Downstream Occupational Exposures

In public locales like airports, restaurants, sports complexes, there is also the added burden flushing these types of products, including wipes, pose on plumbing systems. As such, many facilities post signs in restrooms and stalls to not flush any item other than toilet paper. This is adding to the disposal of used and discarded personal hygiene items into disposal containers. The increasing use of “flushable” tampons and wipes have caused serious clogging problems in waste water and pumping stations so there are national campaigns and movements to build awareness of this issue and direct people to no longer flush these items down the toilet, but rather to dispose of them in trash / waste receptacles. Over time, this change will dramatically increase presence of these items in restrooms and waste streams.

In addition, products which are either disposed of or are flushed down the toilet result in potential occupational exposures downstream. These potential exposures occur to those performing tasks associated with waste / trash handling, transport, incineration, and waste water filtration / processing. While we recognize that each employer is required to determine the hazards specific to their employees in their workplace, proper and safe disposal of personal hygiene products at the source can potentially reduce exposures downstream.

In conclusion

In conclusion, these products, after use, can easily be compressed, leaking blood, body fluids, and OPIM. Given the changing nature of the products, the growing number of people using them and lack of availability of secure, leak resistant liners or individual product disposal bags, potential exposures in many types of workplaces do occur that are frequently under- or unreported.

There are commercially available disposal bags and containers that can be used to dispose of potentially hazardous waste so that employees handling the disposal of such products can be protected from the potentially hazardous contents within. If an employer determines that employees can come into contact with blood, body fluids, or OPIM during the normal handling of such products from initial pick-up through disposal in the outgoing trash, they should consider putting controls in place for such waste. Take a loot at Golden Group International, Ltd to learn more.


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