The urine container disposal conundrum
Recently I received a number of emails from colleagues around the country regarding the disposal of urine containers.
This is a tricky topic because it really depends on the policy at your workplace. OSHA only requires that you dispose of urine containers in red bags if they are contaminated with blood.
This is where HIPPA Privacy Rule comes into play. According to a Department of Health and Human Services FAQ on the disposal of protected health information, “covered entities must implement reasonable safeguards to limit incidental, and avoid prohibited, uses and disclosures of PHI, including in connection with the disposal of such information.”
The FAQ also notes that proper disposal methods may include, but are not limited to, “maintaining labeled prescription bottles and other PHI in opaque bags in a secure area and using a disposal vendor as a business associate to pick up and shred or otherwise destroy the PHI.” Disposing urine samples in red bag waste is one way to fulfill that requirement.
Urine samples typically don’t have a lot of information on them, but they are still considered patient health information. These labels are hard to remove especially with gloves on, and doing so puts the healthcare worker at additional risk for exposure.
So, although the containers themselves are not considered red bag waste, many facilities are requiring they be placed into red bag waste due to the patient’s name and other confidential information that is on the label on the container. Other facilities may attempt to black out the information, but that also raises questions about added exposure.
The bottom line is it’s up to the facility to develop a policy and make sure employees follow it.
What does your facility do? Have you come up with other secure ways of disposing of this patient health information?
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Terry Jo Gile
Terry Jo Gile, MT(ASCP), MA Ed.,The Safety Lady® has more than 40 years experience as a certified medical technologist. As president of her own consulting firm, Safety Lady LLC, she is a world renowned speaker and consultant who helps organizations create safety savvy laboratories. Click the links to visit her Web site and her blog.
Terry Jo has written 49 posts.
Comments
We consider plastic urinals as contaminated waste requiring red bag disposal. 1) there may be microscopic blood not visible to the naked eye and 2) OSHA also refers to OPIM (other potentially infectious material). We consider that any wet/ or used to be wet bodily fluids as OPIM.
We have purchased opaque black labels that we place over the patient name on the cup prior to disposing of in the regular waste can. These cannot be removed.
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