Labelling regulated bloodborne-pathogen waste
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December 13, 1994
MEMORANDUM FOR: FRANK STRANSHEIM
REGIONAL ADMINISTRATOR
FROM: JOHN B. MILES, JR., DIRECTOR DIRECTORATE OF COMPLIANCE PROGRAMS
SUBJECT: CLARIFICATION OF CONTAMINATED WASTE LABELLING REQUIREMENT
The purpose of this memorandum is to provide a clarification on labelling of contaminated waste in accordance with your request dated August 22, 1994.
As I understanding the issue, in the state of California the definition of regulated waste and contaminated waste are identical. It is consistent with the definition used in OSHA's Exposure to Bloodborne Pathogens standard. The Division of Occupational Safety and Health states that, like the federal regulation, the containers regulated waste may be labelled or red bags or red containers may be used to store, transport, or ship regulated waste. The Medical Waste Act seems to go further in proposing that regulated/contaminated waste be both red bagged and labelled. This does not appear to be a conflict as much as it is simply more stringent.
The storage of regulated waste (and "contaminated" waste if the definition is identical) in the workplace do require a label except as provided in paragraph (g)(1)(i)(E),(F) and (G).
We hope this information is responsive to your concerns. If you have further questions, please feel free to call [the Office of Health Enforcement at (202) 693-2190].
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[Corrected 12/6/2024]
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