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Are Feminine Hygiene Products Considered Regulated Waste according to the OSHA Bloodborne Pathogens Standard?

Data Researched and Prepared by Roger McFadden
Senior Scientist, Staples, Inc.

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.  

OSHA expects these products to be discarded into waste containers that are properly lined with plastic or wax paper bags. Such bags should protect the employees from physical contact with the contents.

At the same time, it is the employer's responsibility to determine the existence of regulated waste. This determination is not based on actual volume of blood, but rather on the potential to release blood, (e.g., when compacted in the waste container). If OSHA determines, on a case-by-case basis, that sufficient evidence of regulated waste exists, either through observation, (e.g., a pool of liquid in the bottom of a container, dried blood flaking off during handling), or based on employee interviews, citations may be issued.