Compliance Methods

In 1985, The Centers For Disease Control (CDC) developed the strategy of "universal blood and body fluid precautions" to address concerns regarding transmission of Human Immunodeficiency Virus (HIV) in the health-care setting.  The concept, now referred to simply as "universal precautions" stresses that all patients should be assumed to be infectious for HIV and other bloodborne pathogens.  In areas of health care, public safety, emergency response and biological research, "universal precautions" should be followed when workers are potentially exposed to human blood, certain other body fluids (amniotic fluid, pericardial fluid, peritoneal fluid, pleural fluid, synovial fluid, cerebrospinal fluid, semen and vaginal secretions), or any body fluid visibly contaminated with blood.

Since HIV and Hepatitis B Virus (HBV) transmission have not been documented from exposure to other body fluids (feces, nasal secretions, sputum, sweat, tears, urine, and vomitus), "universal precautions" do not, under current OSHA guidance, apply to these fluids, unless visibly containing blood.  "Universal precautions" also do not currently apply to saliva, except in the dental setting, where saliva is likely to be contaminated with blood.

Universal precautions will be observed at San Juan College, in order to prevent contact with blood or other potentially infectious materials.  All blood and body fluids, as defined above, will be considered infectious regardless of the perceived status of the source individual. 

Engineering and work practice controls will be utilized to eliminate or minimize exposure to all affected persons at SJC. 


The following engineering controls will be utilized: 





Sharps containers

Supervisor’s or Lead Instructor’s Office

Biohazard Disposal Bags

or other accessible location

Blood Spill Cleanup Kit


The above controls will be examined and maintained on a regular schedule.  The schedule for reviewing the effectiveness of the controls is as follows: 



Review Frequency




Sharps Containers



Biohazard Disposal Bags



Blood Spill Cleanup Kit


Replace after use

           1.         SHARPS CONTAINERS 

Sharp items, such as broken glassware, broken knives, needles, or similar material that may be contaminated, and puncture the skin, shall be properly discarded immediately.  Do not pick up sharp items directly with the hands.  Sweep or brush the material into a dustpan and dispose of in an approved  plastic, impermeable sharps container.  All sharps containers shall be closable, puncture-resistant, leak-proof on sides and bottom, and labeled with a "Biohazard" label.  Containers shall be maintained upright throughout use and replaced routinely or when 2/3 full.



Biohazard disposal bags shall be closable and leakproof.  The bags will be either red or red-orange in color and have a biohazard label affixed to it.


Hand washing facilities shall be available to all employees who may reasonably anticipate incurring exposure to blood or other potentially infectious materials.  OSHA requires that such facilities be readily accessible after incurring exposure. 


The department or program supervisor, or designee on duty, is responsible for ensuring that equipment which has become contaminated with blood or other potentially infectious materials shall be decontaminated as necessary unless the decontamination of the equipment is not feasible. 

All contaminated surfaces will be decontaminated as soon as feasible after any spill of blood or other potentially infectious materials, as well as the end of the work shift if the surface may have become contaminated since the last cleaning. 

Decontamination can be accomplished using a 1:10 dilution of household bleach, or other EPA approved disinfectant. 


All personal protective equipment used at this facility will be provided without cost to employees.  Personal protective equipment will be chosen based on the anticipated exposure to blood or other potentially infectious materials.  The Supervisor on duty shall ensure that appropriate PPE in the appropriate sizes is readily accessible at the work site. 

The protective equipment will be considered appropriate only if it does not permit blood or other potentially infectious materials to pass through or reach the employees' clothing, skin, eyes, mouth, or other mucous membranes under normal conditions of use and for the duration of time for which the protective equipment will be used. 


PPE Required



Cleanup and decontamination in connection with minor accidents, such as cuts, scrapes, etc.

Blood Spill Kit to include gloves and apron



Disposal of biohazard waste from reusable containers




Laundry of contaminated material

Gloves and apron


NOTE:  The Supervisor, or designee on duty, shall ensure that any employee rendering aid uses appropriate PPE unless the supervisor can show that the employee temporarily and briefly declined to use personal protective equipment when, under rare and extraordinary circumstances, it was the employee's professional judgment that in the specific instance its use would have prevented the delivery of health care or public safety services or would have posed an increased hazard to the safety of the worker or co-worker.  When the employee makes this judgment, the circumstances shall be investigated and documented in order to determine whether changes can be instituted to prevent such occurrences in the future. 

All personal protective equipment will be cleaned, or disposed of by the college at no cost to the employees.  All repairs and replacements will be made by SJC at no cost to employees. 

All PPE will be removed by employees before they leave the work area.  Other contaminated PPE, such as face masks or aprons, should be taken off in such a way as to prevent the touching of the contaminated surfaces. 

Gloves and disposable aprons shall be disposed of in a biohazard bag. 

When PPE is removed, it shall be placed in an appropriately designated area or container for storage, decontamination, or disposal. 

1.         GLOVES 

Gloves shall be worn where it is reasonably anticipated that employees will have hand contact with blood, other potentially infectious materials, non-intact skin, or mucous membranes; and when handling contaminated items or surfaces. 

Disposable single use gloves used are not to be washed or decontaminated for re-use and are to be replaced as soon as practical when they become contaminated, if they are torn, punctured, or when their ability to function as a barrier is compromised. 

Gloves should be removed by grasping the outside wrist area of one glove using the other gloved hand.  Take care not to touch skin or clothing with contaminated gloves.  Pull the grasped glove inside out and hold onto it with the remaining gloved hand.  Take the ungloved hand reach inside the wrist part of the remaining glove.  Pull the remaining glove inside out.  In this way, the gloves should be one inside the other and the contaminated surfaces wrapped inside.  Place contaminated gloves into the biohazard bag provided. 

Utility gloves may be decontaminated with 1:10 bleach or EPA approved disinfectant.  However, utility gloves will be discarded if they are cracked, peeling, torn, punctured, or exhibit other signs of deterioration or when their ability to function as a barrier is compromised. 

After removal of personal protective gloves, employees shall wash hands and any other potentially contaminated skin area immediately, or as soon as feasible, with soap and water.  If employees incur exposure to their skin or mucous membranes, then those areas shall be washed or flushed with water as appropriate as soon as feasible following contact. 


Masks, in combination with eye protection devices, such as goggles or glasses with solid side shield, or chin-length face shields, are required to be worn whenever splashes, splatters, or droplets of blood or other potentially infectious materials may be generated and eye, nose, or mouth contamination can reasonably be anticipated. 

3.         GOWNS/APRONS 

Gowns or aprons which are impervious to fluids shall be worn when sorting and washing contaminated laundry.  Disposable gowns or aprons used are not to be washed or decontaminated for re-use, and are to be replaced as soon as they are torn, punctured or when their ability to function as a barrier is compromised. 

Place contaminated gowns/aprons into the biohazard bag provided. 


"Potentially Infectious Medical Waste" or "PIMW" means the following types of waste generated in connection with the diagnosis, treatment (i.e., provision of medical services), or immunization of human beings or animals; research pertaining to the provision of medical services; or the provision or testing of biologicals: 

Cultures and Stocks.  This waste shall include, but not be limited to, cultures and stocks of agents infectious to humans, and associated biologicals; cultures from medical or pathological laboratories; cultures and stocks of infectious agents from research and industrial laboratories; wastes from the production of biologicals; discarded live or attenuated vaccines; or culture dishes and devices used to transfer, inoculate, or mix cultures. 

Human Pathological Wastes.  This waste shall include, tissue, organs, and body parts, body fluids that are removed during  medical procedures; or specimens of body fluids and their containers.

Human Blood and Blood Products.  This waste shall include discarded human blood, blood components (e.g., serum and plasma), or saturated material containing free flowing blood or blood components. 

Used Sharps.  This waste shall include, but not be limited to, discarded sharps used in animal or human patient care, medical research, or clinical or pharmaceutical laboratories; hypodermic, intravenous, or other medical needles; hypodermic or intravenous syringes;  pasteur pipettes; scalpel blades; or blood vials.  This waste shall also include, but not be limited to, other types of broken or unbroken glass (including microscope slides and cover slips) in contact with infectious agents. 

Infectious Animal Waste.  This includes discarded materials including carcasses, body parts, body fluids, blood, or bedding originating from animals inoculated during research, production of biologicals, or pharmaceutical testing with agents infectious to humans. 

Isolation Waste.  This waste shall include discarded materials contaminated with blood, excretions, exudates, and secretions from humans that are isolated to protect others from highly communicable diseases.

Unused Sharps.  This waste shall include, but not be limited to, the following unused, discarded sharps; hypodermic, intravenous, or intravenous syringes; or scalpel blades.

Potentially infectious medical waste does not include

Waste generated as general household waste; 

Waste (except for sharps) for which the infectious potential has been eliminated by treatment (e.g., autoclaving, as long as sterilization is documented); or 

Waste animals or animal parts that do not meet the above PIMW definitions (e.g., are not infectious to humans); such waste animals, because when used in college labs are typically contaminated with formalin, should be double bagged in standard garbage bags, and labeled "Waste Animals" for pickup and disposal as chemical waste.  Such separation of excess liquid chemical waste and animals must be done before Campus Security may pick it up for disposal. 

The reader is referred also to the San Juan College Chemical Hygiene Plan for additional information on the safe use, storage, and disposal of chemicals. 

All potentially infectious medical waste shall be placed in containers that are closeable, constructed to contain all contents and prevent leakage of fluids during handling, storage, transportation or shipping. 

The container shall be placed in a secondary container if leakage of the primary container is visible.  The second container shall also be closeable, constructed to contain all contents and prevent leakage during handling, storage and transport, or shipping.  A new container must be placed in the area before the full container is removed.

The container must have a biohazard label, color coded red or red orange.  It must be closed before removal to prevent spillage or protrusion of contents during handling, storage, transport. 

PLEASE NOTE:  It is IMPERATIVE that Biohazard waste NEVER be mixed with chemical ("Hazardous") waste for disposal purposes.  Chemical waste, including waste animals that do not meet the definition of PIMW, especially liquids, must not be placed in "Biohazard" (red) bags for disposal.  Not only does this create an unacceptable degree of hazard (in that the bags will leak), separate disposal companies, neither of which can take "mixed waste", handle these two different types of wastes!  Disposal of all PIMW (Biowaste) shall be in accordance with all applicable federal, state and local regulations.  Check with the Office of Health & Safety (OHS -3775) for more information on disposal requirements. 


Soiled linen should be handled as little as possible and with minimum agitation to prevent gross microbial contamination of the air and of persons handling the linen.  All soiled linen should be appropriately bagged at the location where it was used.  Linen soiled with blood or body fluids should be placed and transported in biohazard bags that prevent leakage.  If hot water is used, linen should be washed with detergent in water at least 71o C (160o F) for 25 minutes.  If low-temperature (#70o C [158o F]) laundry cycles are used, chemicals suitable for low-temperature washing at proper use concentration should be used.

Gloves and an apron should be used when initial sorting and washing is performed. 

If your department ships contaminated laundry off-site to a second facility that does not use Universal Precautions in the handling of all laundry, contaminated laundry must be placed in bags or containers that are labeled or color-coded.  One possible solution would be to include a requirement in the laundry contract scope of work requiring the laundry to use the equivalent of Universal Precautions.


Gary Lee
San Juan College

Environmental Health Office
4601 College Blvd.
Farmington, NM  87401
(505) 566-3775