The Security Rule under the US Health Insurance Portability and Accountability Act (HIPAA) requires dental…
Most dental offices do not generate “red-bag” biohazardous waste, also known as regulated medical waste. Cal/OSHA’s Bloodborne Pathogens (BBP) Standard (Title 8 CCR Section 5193) and the California Department of Public Health’s (CDPH’s) Medical Waste Management Act (MWMA) each have a unique, yet similar, definition for regulated “red-bag” “biohazardous” medical waste.
In the BBP Standard, Cal/OSHA defines regulated “red-bag” medical waste as “liquid or semi-liquid blood or OPIM (other potentially infectious material); contaminated items that either contain liquid or semi-liquid blood or are caked with dried blood or OPIM, and are capable of releasing these materials when handled or compressed; contaminated sharps; and pathological and microbiological wastes containing blood or OPIM.”
What regulated medical waste is NOT according to the BBP Standard… in Cal/OSHA’s “Frequently Asked Questions about the Bloodborne Pathogens Standard”, Cal/OSHAstates that “in 5193(b), the definition of “regulated waste” makes it clear that some contaminated items may become contaminated with blood or OPIM during the course of their use, but are not within the scope of regulated waste and the disposal provisions of 5193. These include minimally contaminated absorbent items, such as dental drapes, gauze, band-aids, and sanitary napkins, that will dry out and be free of dried blood in quantitiesthat could be considered “caked”.”
The MWMA defines regulated “biohazardous” medical waste as “waste that, at the point of transport from the generator’s site or at the point of disposal contains recognizable fluid human blood, fluid human blood products, containers, or equipment containing human blood that is fluid, or blood from animals suspected by the attending veterinarian of being contaminated with infectious agents known to be contagious to humans.”
What regulated medical waste is NOT according to the MWMA… “waste which is not biohazardous, such as paper towels, paper products, articles containing nonfluid blood, and other medical solid waste products commonly found in the facilities of medical waste generators.”
Examples of regulated medical waste found in dental offices that should be disposed of or contained in red biohazard bags include biohazardous waste items that are soaked or saturated with blood or saliva (i.e. gauze saturated with blood following oral surgery), extracted teeth without amalgam if not to be given back to the patient, and surgically removed hard and soft tissues. If an item appears capable of releasing blood or OPIM, then it must be disposed of as regulated medical waste.
According to the MWMA, regulated medical waste must be collected and disposed of in biohazard bags, which are disposable red bag that are impervious to moisture and are strong enough to avoid ripping, tearing, or bursting under normal use. The red bags must be labeled with the words “Biohazardous Waste”, or with “Biohazard” and the international biohazard symbol. The labeled red bags must be placed in rigid, labeled containers. If less than 20 lbs of biohazardous “red-bag” waste are generated per month, it may be stored for 30 days if it is above 0°C and for 90 days if below 0°C. If more than 20 lbs per month are generated, then the waste must be stored for no more than 7 days, regardless of the temperature. Regulated medical waste must be transported offsite by a CDPH-approved medical waste hauler.
Minimally-contaminated regular trash is not considered medical waste, but solid waste and can be disposed of in regular solid waste trash containers.
For our OSHA Review subscribers… more information on medical waste management can be found in Sections IV and IX of your OSHA Review binder. Additionally, online resources such as a list of approved medical waste transporters and a list of sharps waste mail-back systems is available for our subscribers on OSHA Review’s websitein the subscribers-only section.
Since 1992, OSHA Review, Inc. has provided dental professionals with comprehensive programs to support regulatory compliance and infection control. We are a registered continuing education provider in the state of California, specializing in Dental Practice Act, infection control, and OSHA training.