Taking Universal Precautions

Contact with potentially contaminated bodily fluids during collection of waste is a significant concern among waste and recycling personnel. While the collection, transportation and disposal of regulated medical or “red bag” waste is a specialized, highly-regulated segment within our industry, inadvertent exposure to blood-borne pathogens in the general waste stream is a potential occupational risk that should never be overlooked. We need to raise workers’ awareness and prevent blood-borne pathogen exposure in the waste and recycling industry, beginning with an overview of the U.S. Occupational Safety & Health Administration (OSHA) standard and discussion of the Center for Disease Control’s Universal Precautions.

Preventing exposures to blood-borne pathogens begins with the effective implementation of OSHA standard 40 CFR 1910.1030. This standard applies to all occupational exposures to blood or other potentially infectious materials (OPIM), defined as human body fluids such as semen, vaginal secretions, cerebrospinal fluid, amniotic fluid or any body fluid that is visibly contaminated with blood. Applying the OSHA blood-borne pathogens standard begins with developing an Exposure Control Plan (ECP), a mandated, written document designed to identify potential sources of exposures and establish actions and behaviors to eliminate or minimize employee exposures.

The ECP must be reviewed and updated annually to include changes to your business processes or procedures as well as the documented consideration or implementation of new technology. Its main elements are:

1. Exposure determination. This is a list of employee classifications, job tasks and procedures in which occupational exposure may occur. The risk assessments are made without regard to personal protective equipment or work practice/operational controls. That can be a standalone assessment or part of a broader, integrated risk assessment of your facilities and operations.

2. Communication of hazards to employees. It is paramount that every employee has documented training and a solid understanding of which fluids present infection hazards and the risks and controls associated with their job, including volunteer first responders. Understand the avenues of potential exposure through the skin and mucous membranes (nose, mouth and eyes) and via punctures from needle sticks, cuts, abrasions or similar injuries. The training puzzle’s final piece is knowing how to protect against such exposures.

3. Following methods of compliance. This includes universal precautions, engineering and administrative controls, personal protective equipment and housekeeping, especially waste handling. Other ECP elements address the Hepatitis B vaccination and post-exposure evaluation.

The golden rule of preventing exposures is the foundation of universal precautions. First and foremost, all blood and OPIM are considered infectious. You must prevent contact by recognizing potential hazards, sound operating procedures and engineering controls and through the use of appropriate personal protective equipment to create barriers between the fluids of concern and routes of exposure.

Employers are required to offer a Hepatitis B Vaccination, at no cost, to any employee involved in an incident where they were exposed to blood or other potentially infectious materials.

4. Recordkeeping. Employers are required to maintain confidential medical records, including written acceptance or declination by the employee of a post-exposure Hepatitis B vaccine. Also, training records and a sharps injury log must be maintained.

Waste collection personnel face many challenges throughout the day. Using universal precautions simplifies incidents by categorizing all blood and bodily fluids as potentially infectious. Being able to recognize hazards, follow proper procedures and use appropriate personal protective equipment will help you safely address whatever you encounter. If you have further questions, contact the National Waste & Recycling Association (wasterecycling.org). If your company handles regulated medical waste, consider joining NW&RA’s Healthcare Waste Institute.

John Haudenshield is the safety director for the National Waste & Recycling Association and may be reached at (540) 589-2975 or [email protected].