Employers have obligations to protect waste management workers from certain hazards. By using best practice strategies and promoting the importance of following and reviewing OSHA’s Exposure Control Plan, employers may be able to substantially decrease the risk of injury and illness associated with BBPs.

Lee Kibeiks


When waste materials are improperly stored, treated or disposed, release of hazardous wastes may result in contamination of the environment. Hazardous waste can also cause injury and illness for employees working in waste management industries. Waste hazards can be chemical, physical and biological. This article will focus on biological hazards to waste workers and explore some best practice strategies in managing employee exposure to Bloodborne Pathogens.


Biological waste has the potential be to be infectious and transmit disease to humans. This infectious waste includes human blood, or OPIM (Other Potentially Infected Materials such as certain bodily secretions, or bodily products that may contain blood). The Occupational Safety and Health Administration (OSHA) enforce a standard that is designed to protect employees from the risks associated with infectious materials that may transmit Bloodborne Pathogens to humans. The Standard (CFR 29 1910.1030) defines what a Bloodborne Pathogen actually is, how employees can be exposed and requirements for employers to protect their workers from risk of injury or illness associated with these pathogens.


What is a Bloodborne Pathogen?

Bloodborne Pathogens (BBP’s) are micro-organisms found in the blood of infected individuals. If these organisms somehow enter another person, either directly into their bloodstream (such as a needle-stick injury) or through mucus membranes (such as the eyes, nose or mouth) there is a potential for that person to become infected. The OSHA Standard refers to some common Bloodborne Pathogens, including Hepatitis B Virus (HBV), Hepatitis C Virus (HCV) and Human Immune Deficiency Virus (HIV).  HBV and HCV are transmitted through infected blood, where as HIV can be transmitted through blood, but also, selected bodily fluids.


Employees working in the waste handling industry face increased risk of exposure to Bloodborne Pathogens due to incorrectly labeled or discarded waste. It is common practice for used syringes and other sharps, or soiled materials to be disposed of as regular waste.  Waste handlers could inadvertently come into contact with these potentially infectious materials. In 1990, a Washington State survey of more than 900 employees working in residential waste collection, commercial waste collection and landfill/transfer stations was conducted to evaluate occupational exposure to infectious waste. The survey concluded that less that 25 percent of employees had received specialist training to deal with medical waste. Ninety percent of the employees surveyed stated that they saw needles, blood and blood-soaked materials such as bandages in the normal waste stream, on a daily basis. The study also revealed that over 70 percent of workers received cuts or scratches from blood-contaminated materials and 20 percent received needle stick injuries. Shockingly, 10 percent of these injuries were not reported to management (Turnberg and Frost, 1990).


What Does the OSHA Bloodborne Pathogen Standard Require?

Employers are required to determine whether their employees have the potential for occupational exposure to Bloodborne Pathogens. Where this is likely, job classifications and specific tasks that create this exposure should be documented.


An employer must develop, implement and monitor an “Exposure Control Plan”. This must be specific to the tasks that are undertaken and include controls to protect workers from exposure to BBPs. Controls must include the use of engineering controls (such as physical barriers, tools for handling waste and correct waste disposal containers), work practices (such as disinfection and personal hygiene procedures) and use the of suitable Personal Protective Equipment (PPE). Suitable PPE must be selected for each task and be able to protect workers from the risk. For example, if there is a risk of infectious materials being splashed, employees should be provided with protective clothing/shoe covers, face shields and gloves at a minimum.


The Exposure Control plan must embrace the principals of “Universal Precautions”. Following Universal Precautions when handling potentially infectious waste means that employees must assume that the materials are indeed infectious and must protect and isolate themselves from that hazard.


Further to this, occupationally exposed employees must be provided with the option to receive a Hepatitis B Virus vaccination. Information must be provided to employees about the disease, how it is transmitted and how effective the vaccine can be to reduce their risk of contracting HBV. The vaccination must be offered at a reasonable time and location and at no cost to the employee. An employee may refuse the vaccination; however, they must sign a “Declination Form” stating that they do not wish to receive it. An employee is also entitled to change their mind and request a vaccination at a later date.


The Exposure Control Plan must also contain procedures for employees and management to follow in the unfortunate event that an exposure occurs. An ‘exposure’ means that an employee was exposed to a situation where they could potentially become infected with a BBP. This can occur through direct contact with biological materials through mucus membranes or from non-intact skin. Where the skin is compromised, through conditions such as eczema, a wound or abrasion, acne or even sunburn, the normal protective barrier is disrupted and can allow infectious materials to enter the bloodstream and potentially infect the individual. Further to the provision of medical assessment, the Exposure Control Plan must also document reporting and record keeping procedures that take privacy requirements into consideration. Employers must also give the health care provider a copy of OSHA’s BBP Standard.


A major component of the BBP Standard involves training. Occupationally exposed employees must be trained before they begin work and also annually (at least) thereafter. The training must include information about the signs/symptoms of BBPs they may be exposed to, the contents of the Exposure Control Plan and where to find it, specific safe work procedures, equipment and PPE. The Exposure Control Plan must also be reviewed annually with input from relevant workers. More information for the detailed requirements under OSHA’s BBP Standard can be found at



Best Practice and BBP

Best practice solutions undertaken in the past have been directed at helping the waste generators (including the public) to properly dispose of their contaminated waste. In 1999 – 2000 Rhode Island Resource Recovery Corp (RIRRC), in conjunction with the Diabetes Foundation of Rhode Island (DFRI) piloted a Statewide residential needle stick disposal program to provide kiosks in various locations. The kiosks were designed to allow safe disposal of sharps. Before the project, in 1999, RIRRC identified and removed approximately 400 pounds of loose sharps from the materials recovery sorting line. This was costly for the recovery center as production was shut down whenever a needle was identified and during this period, five needle stick injuries were reported. In 2002, after the introduction of the kiosks, RIRRC found 50 percent less needles in the waste stream and reported no needle stick injuries (between the start of the project and 2002). Since this time, several states have adopted similar projects. More information about the kiosks or drop-off locations in each State can be found by contacting The Coalition for Safe Community Needle Disposal (www.safeneedledisposal.org) or The Centers for Disease Control (CDC) (www.cdc.gov/needledisposal).


It may not be feasible for all waste handling facilities to have access to similar, funded programs and without these in place, best practice strategies will need to focus on internal risk controls. Further to the development of the required Exposure Control Plan and associated training, employers should proactively involve employees in hazard identification, assessment of risk and selection of suitable risk controls. Ensure that employees are provided with sufficient information about BBPs. Inform employees about the potential diseases, how they can be exposed and how they can protect themselves. It is vital to provide this information in languages other than English when required.


Also, ensure that supervisors follow the safe work procedures and use engineering controls and PPE that are provided to set an example. Provide sufficient time for employees to follow the requirements in the Exposure Control Plan and ensure that refresher training is provided in a timely manner. Employers should promote the importance of the Exposure Control Plan and seek input from employees on a regular basis. Ensure that all exposures, and near misses are reported and investigated and follow-through with required risk controls.


Protect Your Workers

Employees in the waste handling industry are exposed to various hazards, including illness associated with BBPs. Employers have obligations under OSHA’s BBP to protect workers from these hazards. By using best practice strategies and promoting the importance of following and reviewing the Exposure Control Plan, employers may be able to substantially decrease the risk of injury and illness associated with BBPs.


Lee Kibeiks currently works as a Safety and Compliance Consultant with HazCommpliance, LLC (Enfield, CT), a company that provides quality occupational, safety and health services. Lee has more than 15 years of international experience in both safety enforcement and consultancy roles in a variety of industries. She can be reached on (860) 253-0050, via e-mail at [email protected] or visit www.hazcommpliance.com.




  • OSHA BBP Standard 1910.1030
  • Caranci, et., al (2002). Eureka – Implementing Safe Community Needle Disposal in Rhode Island. J Am Pharm Assoc. 2002;42(suppl 2): S109-10
  • Turnberg and Frost (1990). Survey of Occupationally Exposed Waste Industry Workers to Infectious Waste in Washington State. AJPH Oct 1990. Vol. 80, No. 10.