Stacey Freed

When Darrell Hicks, author of Infection Prevention for Dummies, was the director of environmental services at a 500-bed hospital in the Midwest, he knew that one of the least sanitary spots in the women’s bathroom was the feminine hygiene receptacle. “We had a chrome container and what we referred to as ‘lunch bags,’ paper sacks lined with wax that made them impervious to wetness,” he says. But his janitorial staff didn’t like the odors emitted when they opened the box to clean it. They didn’t like to see what was inside, and they “didn’t want to come into contact with gross stuff,” he says. But these concerns shared by Hicks extend beyond having to dispose of the waste, and rather, bring up possible exposure to bloodborne pathogens (BBPs) lurking inside and on the container. Addressing the Risks Feminine waste receptacles “are sometimes lined, sometimes lined with a bag that doesn’t hold its form to conceal the waste, sometimes unlined, sometimes streaked with what appears to be blood or bodily fluids," says Ann Germanow, founder and CEO of The Scensible Source Co., which provides solutions for the disposal of feminine care products in restrooms. “They smell and that can be an indication the receptacle is contaminated with odor-causing bacteria.” Germanow, too, is concerned about the hazards of possible infection for cleaning staff and restroom users. “I say, ‘Better safe than sorry,’ when it comes to maintaining a communal trash can that holds discarded materials with blood and body fluids in restrooms.” While protocols should be in place to clean the restroom, it’s important that employees know to pay special attention to the feminine hygiene waste receptacle. “Everything is potentially infectious. Just because it’s not visible doesn’t mean there isn’t something on that surface,” Hicks says. But how do you ensure that your employees are following the right procedures to keep themselves and others safe? Educate and Train Angella Luyk, CEO of Midnight Janitorial in Rochester, NY, says education is key. “Make sure your employees know why they’re doing things a certain way,” says Luyk, whose 63 employees (about a quarter of whom have developmental disabilities) clean 50 buildings. She has her operations manager and two supervisors train employees from “day one.” The managers go through a manual with employees during a week-long training process. “We show them what to do, watch them, and ask questions. At the end, [the employees] sign off on a sheet saying they’ve learned all the procedures,” Luyk says. Employees are also required to watch a video, given to them from Luyk’s insurance agent, which trains them in cleaning bloodborne pathogens. “We talk with them about why they have to wear gloves and remove them each time.” When it comes to the feminine hygiene receptacle, she says, “We help them understand why they should never dump out a bag and reuse it or why they shouldn’t shove a whole bunch of bags into the dispensers.” To make sure staff complete tasks properly, each facility is checked once per week by Luyk’s operations manager who marks items on a spreadsheet. “On-site checklists [that are signed by the employees] don’t work,” she says. “We randomly pop our heads in and ask employees to show us what they’re doing. Sometimes we send in a ‘spy’ to be trained in cleaning procedures by an employee.” Hicks suggests trainers make sure employees understand the difference between cleaning and disinfecting. “Cleaning ought to precede disinfection,” he says. Sometimes the bio burden of the blood or bodily fluid on a surface is greater than a disinfectant can handle. “If you clean something first and remove 95 percent of the soil, the disinfectant has a better chance to kill the amount that’s left. Use a good cleaner and a microfiber cloth.” At the site of the feminine waste receptacle, Hicks suggests using “something with a [Hepatitis B] claim on it, but I’d advocate an intermediate disinfectant that will kill higher strains of organisms, something that’s tuberculocidal and sporicidal to kill C. diff spores. If it kills that, it will kill everything [less hardy] than that.” Measure Cleanliness Levels Once the work is done, you need to “measure clean,” Hicks says. He suggests using either the fluorescent marking method followed by a black light inspection or using an ATP meter, which measures growing microorganisms by detecting adenosine triphosphate. “It’s not a ‘gotcha’ moment,” he says. “You have to show employees that they just have to slow down and get at those surfaces.” He adds, “People think that if you can clean your room at home you can clean the bathroom at McDonalds. Give your people the whys and they’ll understand the how-tos better. There’s too much stuff flying under the radar of public health until there’s an outbreak.” ISSA’s Cleaning Industry Training Standard (CITS) program will verify your training program, says Hicks, who also teaches an infection prevention course that is verified by ISSA, the worldwide cleaning industry association. “It will let you know if the training that you, product manufacturers, distributors, and other private companies are giving your employees meets industry standards.” Setting Standards And yet, there is no real standard for cleaning feminine hygiene receptacles. The U.S. Occupational Safety and Health Administration (OSHA) doesn’t consider discarded feminine hygiene products to fall within the definition of “regulated” waste, since feminine hygiene products purportedly “absorb and contain blood” and "prevent the release of liquid or semi-liquid blood or the flaking off of dried blood,” according to an OSHA spokeswoman. OSHA's expectations leave all the responsibility to the employer, she adds. “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

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Stacey Freed

Stacey Freed is a freelance writer living near Rochester, NY.

Articles by Stacey Freed

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