The Basics of Medical Waste and Disposal
A variety of industries generate medical waste, from hospitals and veterinary clinics to tattoo and body piercing parlors. Understanding what medical waste is and how to properly dispose of it will not only help you keep workers and the public safe, it will also help you be in compliance with government and industry standards. Let’s look into the specifics.
What is Medical Waste?
Medical waste is any type of waste that could potentially be infectious. The United States Code defines medical waste as "Isolation wastes; infectious agents; human blood and blood products; pathological wastes; sharps; body parts; contaminated bedding; surgical wastes and potentially contaminated laboratory wastes; dialysis wastes; and such additional medical items as the Administrator shall prescribe by regulation."
Another more basic definition is that medical waste is “generated as a result of patient diagnosis and/or treatment or the immunization of human beings or animals.”
These definitions are the general consensus of regulatory agencies such as the Occupational Safety and Health Administration (OSHA), Department of Transport (DOT), Environmental Protection Agency (EPA), as well as state and local agencies. Some agencies use the term “Regulated Medical Waste” meaning medical waste that “contains enough blood or other potentially infectious materials (OPIM) to potentially spread bloodborne pathogens.”
It is important to note that there is no national standard, and you will often find that regulations overlap. Any generators of medical waste should check with their local and state authorities to see their locality’s regulations for disposal and transport of medical waste, as they can vary state to state, county to county.
Is Medical Waste Hazardous Waste?
The Resource Conservation and Recovery Act (RCRA) is the federal law that establishes the categories of hazardous waste, as well as the management standards for facilities that produce hazardous waste. Under this Act medical waste is determined to be hazardous waste. The EPA has authority under this act to regulate the handling, storage, and treatment of medical waste.
To find further definitions, and to see what regulations you are expected to be in compliance within your specific county and state, it is imperative that you check your county and state’s requirements. Be sure to check out the requirements of federal agencies as well, like OSHA, the EPA, and DOT, so you can avoid potentially heavy fines.
What are the Types of Medical Waste?
The EPA defines medical waste as a “subset of wastes generated at health care facilities, such as hospitals, physicians' offices, dental practices, blood banks, and veterinary hospitals/clinics, as well as medical research facilities and laboratories.” Generally, medical waste is healthcare waste that may be contaminated by blood, body fluids or other potentially infectious materials and is often referred to as Regulated Medical Waste (RMW).
There are two categories of medical waste: Red Bag and Sharps. Red Bag is the receptacle used for contaminated or potentially contaminated materials that contain blood or Other Potentially Infectious Materials (OPIM) on it. Sharps containers are for contaminated sharps, such as hypodermic needles, scalpels, and etc. These containers must be puncture-resistant, closable, and are supposed to be kept upright to prevent sharps or liquids from spilling out.
Medical waste doesn’t just come from big hospitals and industrial facilities. Many small and medium-sized businesses are low volume producers of medical waste. Some of these include:
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Clinical Laboratories
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Pharmaceutical Companies
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Body Art Parlors
OSHA has further classifications and descriptions of the types of medical waste according to 42 US Code § 6992a, which you can view here.
What are the Risks of Medical Waste?
After bags of syringes reportedly washed up on American beaches in the 1980s, the public cried out for medical waste reform. This led to the federal government assessing the situation in a “cradle to grave” investigation, culminating in the Medical Waste Tracking Act of 1988.
This tracking sought to establish medical waste’s true threat to the public, and to employees who work in waste-generating environments. The act expired in 1991, leaving regulation more of a state responsibility, but did reveal that the ones who are most at risk from medical waste are the employees working with it.
Primarily, “disease transmission by contaminated sharps” poses the most significant risk to those administering treatment within the clinical environments, during laboratory procedures, or during initial disposal. OSHA estimates that “5.6 million workers in the healthcare industry and related occupations are at risk of occupational exposure to bloodborne pathogens (via) sharp devices or equipment such as scalpels, sutures, hypodermic needles, blood collection devices, or phlebotomy devices”.
General danger to the public is also an issue when medical waste is not segregated and disposed of properly, with toxic and infectious waste sometimes ending up in landfills. These issues are why federal, state, and local governments impose regulations and fines. The integrity of medical waste generators as well as potential heavy financial consequences make it critical that you know the law and comply.
What are “Universal Precautions”?
Universal Precautions are a set of infection control strategies that treat human blood and some bodily fluids as if they were all highly infectious. Medical specialists using this method then act accordingly when coming into contact with blood and fluids.
According to OSHA’s Occupational Safety and Health Standards, some of these fluids are:
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Blood
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Semen
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Vaginal secretions
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Cerebrospinal fluid
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Synovial fluid
These fluids have the potential to transmit many diseases, including but not limited to:
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HIV
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Hepatitis (A, B, and C)
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Staph Infections
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Strep Infections
Using the Universal Precautions method, those coming into contact with these fluids should assume all of them have the potential to be infectious. As a result, they must take the proper precautions when dealing with any of these fluids, even if there is no apparent evidence that they are infectious (hence the words “Universal” and “Precautions”).
The CDC lists some precautionary practices one could take when coming into contact with certain bodily fluids, including:
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Wearing barrier gowns
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Wearing gloves
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Wearing protective eyewear
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Wearing masks and face shields
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Washing hands thoroughly
Though not everyone has infectious blood or bodily fluids, the Universal Precautions method treats most blood and fluid as infectious in order to ensure total safety. This could be necessary when dealing with fatal diseases or pathogens, the slight outbreak of which could cause death.
What are the Medical Waste Regulations?
Federal Regulation
Federal agencies such as OSHA, DOT, and EPA all play a role in regulating medical waste disposal. However it is primarily regulated by state environmental and health departments.
State Regulations
Each state has its own regulations since the Federal regulations have expired. The following links are to a summary of the state by state regulations.
http://www.hercenter.org/rmw/osha-bps.php
http://www.hercenter.org/osha.php
We also have a handy list of the same information on our resources pages.
The regulations imposed by state and local government bodies would be too numerous to list here. However, more information can be found about state requirements here. Although there are no federal standards regulating medical waste, the states all tend to utilize OSHA’s verbiage when defining what constitutes medical waste. For the most part, states follow the Universal Precautions. However, it is vital to check with your local and state regulations as each state is quite unique, with regulations ranging from broad to very strict.
Other Federal Regulations
The Resources Conservation and Recovery Act (RCRA) regulates hazardous waste management through the Code of Federal Regulations (CFR). The EPA and the DOT regulate these activities through 40 CFR and 49 CFR, respectively.
There are also laws imposed at the local and municipal level. Many of these medical waste laws overlap. Some of the laws at the state and local level are sometimes more stringent. It is important for medical waste generators to check with all of the listed entities to ensure they are compliant as fines can range in the tens of thousands of dollars.
Each agency regulating medical waste has its own way of influencing the industry, and each one is usually involved with a specific part of waste management and disposal.
For instance, OSHA regulates employee training on medical waste handling and container labeling, as well as the requirements for the disposal of sharps.
The DOT dictates how medical waste should be packaged and labeled during transportation. The department also has specific hauling licenses on transport trucks and dictates truck specifications and cleaning regulations.
The EPA generally looks after waste treatment technologies and maintains the standards for medical waste incinerator emissions. However, due to their tight restrictions there aren’t many incinerators in the US anymore. Most medical waste is disposed of using other technologies.
Medical Waste Generators
What counts as a “Medical Waste Generator”, and how are they regulated?
It all depends on how much medical waste you produce. There are a number of EPA classifications based on the volume of medical waste a facility produces. The EPA advises that “Generators of hazardous waste are regulated (by the EPA) based on the amount of hazardous waste they generate in a calendar month, not the size of their business facility”.
There are two primary classifications: Small Quantity Generators and Large Quantity Generators.
Small Quantity Generator (SQG) - Produce more than 100 kilograms, but less than 1,000 kilograms per month (around 220 lbs to 2200 lbs).
Large Quantity Generators (LQGs) - Produce 1,000 kilograms per month or more.
On their website, the EPA lists the ways you can ensure compliance according to the type of generator you are. You can create a checklist for your facility based on the following:
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Accumulation Requirements
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Accumulation Time Limits
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Air Emissions
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Contingency Plan and Emergency Procedures
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EPA ID Number
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Facility Type
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Land Disposal Restrictions
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Manifest
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On-Site Accumulation Quantity
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Personnel Training
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Preparedness and Prevention
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Pre-Transport Requirements
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Record-keeping and Reporting
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Quantity Limits
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Waste Minimization
To access the EPA’s full requirements, please see this link.
The EPA also strongly encourages you to check with your state environmental agency as they may have additional or more stringent requirements than the federal government. Please see the EPA’s link below.
Best Practices of Medical Waste Disposal
With its huge medical industry, the United States produces a staggering amount of medical waste. One study reports that American hospitals create 5.9 million tons of waste every year. How are hospitals and medical establishments supposed to manage, and then dispose of, this huge amount of waste?
To begin, healthcare facilities may have to register with the government as a Medical Waste Generator, depending on the state of residence. This is very important, as facilities need to be in compliance with state regulations. Certain procedures for managing and disposing of medical waste could differ depending on the state’s laws.
All facilities, regardless of its state of operation, should consistently separate their waste. Specifically, they should separate the Regulated Medical Waste from general waste. In some states, it’s required by law, but it is still good practice even if it’s not.
When it comes time to dispose of medical waste, there are several different methods one could take, depending on the type of material. Here are some of the most common:
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Incineration: used for pathological and pharmaceutical waste.
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Autoclaving: microwave radiation, used for sharps.
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Irradiation: gamma rays, used for sharps.
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Chemical Decontamination: used for blood and fluid waste
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Onsite destruction using one or a combination of these options.
All facilities are responsible for managing and disposing of their own medical waste, regardless of state regulations. All facilities should practice care and caution when managing their medical waste, taking the time to sort, contain, and dispose of it in a safe and legal manner.