The use of Personal Protective Equipment (PPE) for food safety has been widespread for at least two decades, certainly for gloves, hairnets and facial hair covering. The use of face masks or coverings has also been common in fresh processing, but far less pervasive during this same time frame and generally more frequent outside the U.S. The disposal of PPE on the farm, in packing, and within processing facilities under “normal” operational conditions has been handled as routine waste.
With the necessity for employers to provide risk-appropriate PPE for protection against transmission or acquisition of SARS-CoV-2, a requirement consistent with other worker protection and safety standards (
OSHA COVID 19-Standards; OSHA Employers PPE Requirements Handout #7), additional firm-individualized standard operating procedures (SOPs) and Administrative Controls and Policies are needed for any business generating PPE waste. These operation and risk-based measures are specific to COVID-19 and necessary to establish responses to potentially changing risk exposure conditions for the workforce.
The SOPs should lay out the firm’s responses to dynamic, and often acute, shifts within an operation. Policies need to anticipate the conditions which will determine whether individual and aggregate PPE waste disposal, collection and removal from the facility should be handled as normal solid waste or transition to handling with extra precautions, somewhat like medical waste. Public health agencies recognize this sharp risk contrast but, to date, have not provided specific or detailed guidance for industries not engaged in SARS-CoV-2 testing, handling of presumptive or known specimens, or disposal of PPE waste from such activities.
General guidance is available, and useful resources are provided below. However, the maze of agency information link-loops to PPE waste management are realistically suitable only for operations engaged in health care response and services a certainty of medical waste generation. There are two key components to consider in developing your SOP including removal and disposal of PPE by the general workforce and protection of those responsible for final collection and removal of aggregated, used PPE from the facility.
For the general workforce
Under low risk conditions (
See PMA Guided Self-Check for Recommended Practices to Prevent and Reduce the Spread of COVID-19), solid waste disposal of facemasks, used gloves, forearm coverings, and other single use PPE apparel should be placed in routine lined and lidded or covered receptacles. Ideally, firms should consider using dedicated bins or containers to collect this PPE. Under higher risk conditions where illness or asymptomatic workers have been determined or increases in community prevalence of COVID 19 have been announced (See PMA Self-Check), workers follow waste disposal of facemasks, used gloves, forearm coverings, and other single use PPE apparel using practices more similar to medical waste management. Firms should use dedicated and clearly marked bins or containers to collect this PPE.
Develop specific training and comprehension-supportive signage on PPE removal and disposal for both operational environments and scenarios.
Train workers not to overfill the bins or receptacles to allow for easy closure of the liner by waste management and custodial services workers.
For custodial and waste collection and removal workforce
On-farm and in-shift workers handling used PPE and employed or contracted custodial employees specifically handling aggregated, used PPE should be thoroughly trained on the firm’s policies and procedures for modified medical waste management, developed using the resources provided below.
PPE waste handlers should be specifically informed of personal infection control practices and perform their responsibilities as if the PPE is contaminated, regardless of where it is disposed.
PPE waste handlers should use double-glove protocols, facemasks, and eye protection to collect the solid waste or presumptive SARS-CoV-2 contaminated waste from the specified containers. Liners should be gathered and tightly sealed for transport in a raised-edge or deep-sided and wheeled cart to prevent leaks and spills if liners are damaged.
Under a high-risk condition, such as if testing reveals multiple infected and symptomatic or asymptomatic employees, a medical waste removal service is required to pick up and transport this used PPE for proper decontamination and disposal.
Currently, we find no evidence of specific and authoritative or official guidance for the produce industry on this topic of PPE waste management for COVID 19 by non-medical businesses. We will continue to request, work with, and monitor public health agencies for updates and new releases of relevant materials.
CDC Non-Health Care Facilities
FDA Best Practices for Re-Opening Retail Food Establishments
FDA Best Practices for Re-Opening Retail Food Establishments Infographic
OSHA COVID-19 Standards and Procedures
OSHA Employers PPE Requirements Handout #7
OSHA COVID-19 Interim Enforcement Response Plan
OSHA Workplace Preparedness, Engineering and Administrative Controls
CA Dept. Public Health Notice to Any Business Generating PPE Waste
FEMA Addressing PPE Needs in Non-Healthcare Setting
PMA Guided Self-Check for Recommended Practices to Prevent and Reduce the Spread of COVID-19