Understanding OSHA Regulations for Biohazardous Waste

Gabby MartinBiohazards, Equipment, Jobs, Remediation, Safety, Sanitization

OSHA Hazardous Waste Regulations

Key Points

  • Types of Biohazardous Material

  • Recognizing Biohazardous Materials

  • Evaluating Exposure to Biohazardous Substances

  • Prevention and Control


OSHA Hazardous Waste Laws

Hazardous waste legislation went into effect when the Resource Conservation and Recovery Act (RCRA) was signed October 21, 1976. Its intent was to address the proper handling and disposal of the growing volume of hazardous waste materials. The legislature has been amended several times, including with the Hazardous and Solid Waste Amendments (HSWA) in November 1984.

These laws are regulated and enforced by OSHA, the Environmental Protection Agency (EPA), the U.S Nuclear Regulatory Commission (NRC), the National Institute for Occupational Safety and Health (NIOSH), the U.S. Coast Guard (USCG), and the U.S Department of Transport (DOT). Additional local laws also apply and are usually regulated by the state or municipality’s environmental agency.

Companies like Bio Recovery exist to facilitate the legal handling of all biohazardous materials to keep the environment safe and protect people who work or reside near places where these materials may be present. 

Bio Recovery understands that these are not typical circumstances, and thus, in the event of a situation, being properly informed with clear, accurate information is important. This guide is to make understanding why OSHA regulations are required and why only trained professionals should be exposed easier.

Common Types of Biohazardous Materials

Biohazardous materials are substances or chemicals that pose a physical or health hazard or harm to the environment, even death. These are all potential symptoms of biohazardous exposure:

  • Skin irritation, lumps, or other issues
  • General feeling of “unwell”, lethargy, etc.
  • Eye irritation or severe eye damage
  • Reproductive issues
  • Trouble breathing, wheezing, or other respiratory issues
  • Danger breathing 
  • Mental health symptoms
  • Other targeted health issues

It’s important to note that the risk and symptoms vary depending on the amount, duration of exposure, and how they interact with the animal or person’s age, sex, weight, stress, diet, susceptibility to allergic reactions, medications taken, and offsite exposures (e.g. outside autobody work and/or hobby activities such as refinishing furniture).

These biohazardous materials may be present in many different situations, including emergencies such as crime scenes, accidents, spills, suicides, mold, asbestos, etc. As there can be hundreds of visible and nonvisible hazards in these types of situations, it’s impossible to know exactly how dangerous an area may be. It’s never a bad idea to assume the worst in any situation where exposure has been confirmed or suspected.

Effects on the Environment

The surrounding environment is full of life that we depend on for food, air, and water. Uncontrolled contaminated areas can poison the surrounding plants, wildlife, and freshwater, causing even more disruption and destruction to an area. 

Even the most dangerous situation can be restored to safety when handled according to protocol. It’s when the situation is handled improperly that lives are compromised or lost.

Recognizing Biohazardous Materials

In the biohazard industry, there are many different types of serious hazards. There are biohazards, hazardous materials (aka HAZMAT), deadly bloodborne pathogens, and drugs or drug residue. Recognizing these and knowing the risk of exposure can vary, from simple skin irritation to long-term illnesses like cancer. 

It’s important to note that it’s almost impossible to identify all hazards in the initial stages of suspected exposure, even for the professionals! That is exactly the reason why this section should be used only to provide confidence that you may be exposed, not in an attempt to identify the biohazard to remove it yourself. A professional will need to go over an area several times–and even then–with the hundreds of hazards present at a location–there is a high likelihood of finding more during a cleanout.

A professional entering the area will have:

  • completed hours of training in official courses pertaining hazardous materials and PPE
  • a full understanding of the risk associated with exposure, and;
  • read and understood the site’s Standard Operating Procedures (SOP)

This is done so that dangers can be identified, safely avoided, and completely understood. The SOP should enable the crew to work cohesively, using the correct supplies and equipment.

Common Types of Hazards

Again, while it is impossible to know the hazards at a glance, some of the most commonly present substances and chemicals HAZMAT specialists deal with:

  • Bloodborne, viral, fungal, or bacterial pathogens
  • Asbestos (or asbestiform particles)
  • Illegal drugs
  • 2-Chloroacetophenone (Tear gas)
  • Aromatic compounds (also referred to as “aromatic hydrocarbons”)
  • Halogenated aliphatic hydrocarbons (a chemical)
  • Polychlorinated biphenyls (PCBs)

It is important to note that hoarding situations can contain additional hazards. In extreme hoarding situations, stacks of varied items can off gas chemical substances as the chemical compounds break down or rot from water exposure, thereby releasing potential carcinogens into the environment. An example of this could be a hoard of garden items, from pesticides to herbicides, that have spilled but are inaccessible due to severe hoarding in the home.

Substance

Examples

Health Concerns

Bloodborne, viral, fungal, or bacterial pathogens

Bodily Fluids (e.g. blood)
Emerging Viral Pathogens (e.g. Monkeypox)
Mold

Known to cause serious symptoms to potentially long term fatal illness.

Asbestos

Or Asbestiform particles
Generally found in construction, shingles, tiles, and automotive parts

Linked to cancer, mesothelioma, and other stomach related illness and disease.

Illegal drug residue

Meth, fentanyl, heroin, crack cocaine

Permanent skin or tooth damage, organ failure and death (overdose).

2-Chloroacetophenone

Tear gas
Pepper spray

Excessive visual and eye problems, respiratory issues (runny nose, burning, swelling, chest tightness, shortness of breath). Also known to cause chemical burns, allergic reactions, and potentially cancer. 

Aromatic hydrocarbons

Forensic fingerprint powder
Paint Thinner (Toluene)
Benzene
Xylene

Benzene is especially known for disrupting bone-marrow function. Mental health symptoms, headaches, sleepiness, all have been linked with exposure.

Halogenated aliphatic hydrocarbons

Chloroform
Methyl chloride
Vinyl chloride
Ethyl bromide
Carbon tetrachloride
Types of Refrigerants and Freon

Decreased alertness, headaches, sleepiness, loss of consciousness. Urine issues and anemia are also commonly reported.
Vinyl chloride has been a confirmed known carcinogen, the others are potential carcinogens.

Polychlorinated biphenyls (PCB)

Transformers and capacitors
E-waste
Cable insulation
Motor oil

Various skin problems
Known carcinogens to animals

For a further breakdown, please see how OSHA classifies and disposes of hazardous waste.

Evaluating Exposure

Evaluating exposure is a part of the site characterization process. This process is meant to outline a scene by understanding the predominant hazards in order to limit exposure and protect employees or anyone entering the site. It provides a blueprint for safety, from setting a standard for the appropriate PPE to wear to knowing the limit someone should be exposed to the substance. 

Testing for Exposure

This process also of course includes testing. Testing a substance identifies what it is and eventually clears the area for public entry.

Different tests are used to determine a biohazard or chemical substance.

  • For biohazards, ATP testing is used.
  • For air contaminants, air sampling is used.
  • For all other surface contaminants, the sampling respective to the situation is used. 
  • There are also direct-reading warning devices for certain toxic compounds or field tests. These field tests, sometimes labeled PCR or immunoassay tests, are generally used to classify the appropriate level of PPE. 

Each site is different and so is the variety of dangers present. A trained professional will be able to assess the situation and determine the best test(s) to use. For example, a low airborne contamination might still require surface contamination sampling if skin contact with potential hazards is possible. Each situation is different and must be assessed properly, by a professional.

Limiting Exposure

All substances follow a recommended “ceiling limit” of exposure, or in other words, the maximum time of exposure to the element. The recommendations for each chemical substance can be referenced on OSHA’s website. Chemical substances like Asbestos follow strict protocol and exposure limits, all which can be found in 29 CFR 1929.1101.

Wearing the Appropriate Personal Protective Equipment (PPE)

An important part to limiting exposure and protecting public safety is ensuring anyone entering a site, including employees, have appropriate Personal Protective Equipment (PPE).  A professional will know which PPE to wear after assessing the level of danger, which are based on laboratory settings.

There are several levels of PPE, labeled from A-D: 

  • Level A: The highest level of PPE, generally suited for major incidents e.g. Ebola exposure
    • Pressure-demand, full facepiece SCBA or pressure-demand supplied air respirator with escape SCBA.
    • Fully encapsulated vapor and chemical protective suits
    • Air respirators
    • Face masks
    • Outer and inner chemical-resistant gloves
    • Safety boots/shoes
    • Two way radio
  • Level B: Suitable for incidents that require less skin protection than level A. The difference is the suit does not have to be encapsulating and a hard hat is worn. These situations are best for any incident where the atmosphere is less than 19.5% oxygen because of the superior respiratory protection with minimal physical restriction. These incidents are usually crawl spaces.
  • Level C: Same level of skin protection as Level B with less respiratory protection (a face shield and escape mask is optional).  Some technicians may wear level C PPE when transporting already contained biohazard drums or containers.
  • Level D: The minimal amount of skin and respiratory protection. An example might include wearing a face mask, gloves, and safety shoes while working on a car.

Levels of PPE may be interchanged depending on the hazards present at a situation. Again, a trained professional should be able to evaluate the dangers with the correct information.

Control and Prevention

Due to their dangers, OSHA has specific procedures to effectively and safely control and prevent biohazards. This is to minimize potential contamination and contain any dangers from the unprotected public. The OSHA procedures to control exposure include:

  • Creating a site map
  • Prepping the area
  • Establishing work zones
  • Establishing and enforcing decontamination procedures for personnel and equipment
  • Establish security measures
  • Have and test communication networks
  • Enforce safety protocol and SOP

Some steps may be removed or added depending on the needs of the job. Again, an experienced professional should be able to plan and adjust the site control as necessary.

For example, a standard size home may not require a full scale composite site map, although industrial situations where the contamination is wider spread or full of multiple safety issues, this may be necessary. Each situation is different and as work is conducted new controls may be required, such as additional work zones not originally accounted for.

Common Types of Work Zones

Site work zones have several uses and purposes, from protection to containment. Most often technicians use these zones to organize and prevent the spread of contamination. A site may have several work zones, all which are clearly marked at the site and dedicated to their intended operation. Professionals ordinarily have three most frequently used zones:

  • Exclusion Zone: the contaminated area
  • Contamination Reduction Zone (CRZ), or the zone for decontamination
  • Support Zone: an uncontaminated area, usually outside of the area entirely. For example, this can be a work truck parked in the lot, or an EMS station outside the Contamination Reduction Zone (CRZ).

Zones are tested and monitored throughout the job to ensure safety and personnel PPE may vary depending on the operation and conditions. For example, someone collecting samples towards the outer edge of the Exclusion Zone may wear Level C PPE while technicians deeper in the zone may wear Level B PPE. It all depends on the job and the safety required in the work area.

Decontamination

Decontamination procedures are not just important for the job; it’s important to the technician as well. During the job, contaminants on the PPE can permeate and lead to unexpected exposure.  A fully licensed professional will know how long equipment should be worn, when to decontaminate equipment, what to decontaminate it with, and when to dispose of the equipment (and where). 

An overlooked issue with amateur cleanings is that equipment and supplies are not properly decontaminated during the job, increasing the likelihood that contaminants will be spread.

Prevention

Prevention is an important part of the Standard Operating Procedure (SOP). Its goal is to minimize and contain exposure. A few professionals practice prevention is by:

  • ensuring work practices are followed and enforced
  • sample and monitor frequently
  • properly contain and dispose of any contaminated materials (including PPE).

The containment and disposal of contaminated material is extremely important for safe transportation and to the protection of waste facility professionals.

Who We Are

Taking matters into your own hands is a huge health risk not only for you but the surrounding public. The good news is there is really no reason you have to. Bio Recovery is a fully OSHA compliant and certified professional biohazard company with over 20 years experience.

Bio Recovery crews complete the required 24 hour HAZMAT and HAZWOPER certification courses annually to stay up to date on the latest safe cleaning, restoration, removal, and transportation procedures. Furthermore, most situations are considered “no fault” and completely covered by insurance, so there is no cost to you.

Bio Recovery is a nationwide network of emergency HAZMAT and biohazard professionals.
Please do not hesitate to contact us at any time, 24/7, for immediate assistance.

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