Does OSHA consider feminine hygiene products medical waste?

The terms “biohazardous material,” “biohazardous waste,” “medical waste,” “regulated waste,” and “regulated medical waste” are used somewhat interchangeably, but they all have different definitions, and how they’re defined is usually based on what state you live in.

One concern we’ve come across here at Red Bags is in which category do feminine hygiene products belong?

While feminine hygiene products are not considered medical waste, it begs the question: when they are handled by another person, like personnel emptying the bathroom trash, does OSHA consider this medical waste? In this situation, wouldn’t the employee be exposed to potential bloodborne pathogens?

OSHA has had several requests about feminine hygiene products, and has provided the following answer:

“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.”

The Bloodborne Pathogen Standard (BBP), per OSHA, puts it on the employer to determine the existence of medical waste.   This determination should not be made based on the volume of blood, but rather on the potential to release blood.  Because sanitary napkins and tampons are designed to absorb blood, they aren’t considered a risk.  Likewise, OSHA also states that bandages which are not saturated to the point of releasing blood or other potentially infectious materials (OPIM) if compressed is not considered biohazardous waste.  This is the same for feminine hygiene products, therefore they do not normally meet the criteria for medical waste as defined by the BBP standard. 

In Delaware, potentially hazardous waste, includes soiled diapers and feminine hygiene items, and food wastes. These are not, however, considered medical waste.

It all comes down to containment and what disposal receptacles are available. Many facilities rely on wax paper liners in a designated waste container while others prefer plastic liners.

For cleaning purposes, this is where personal protective equipment (PPE) comes in handy; staff should use nitrile gloves to empty and clean the receptacles and disinfect the inside and the outside of feminine hygiene containers by spraying a disinfectant and then wiping the receptacle with a disposable paper towel.

Red Bags is proud to assist companies with their medical waste questions, as well as other compliance and safety topics. We offer an online OSHA Compliance Training program, which can help your facility understand the importance of PPE, as well as infection control practices.

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