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Guidelines for Medical Waste Management

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Guidelines for Medical Waste Management

Proper medical waste management is critical to ensure the protection of people, animals, and the environment from the potential exposure and transmission of hazardous communicable diseases. There are specific local, state, and federal guidelines designed to assist those that generate medical waste. Each state has established laws that define and/or compliment federal laws, and generators of medical waste must also coordinate with other federal agencies for compliance including but not limited to: OSHA (Occupational Safety and Health Administration), DOT (Department of Transportation) and EPA (Environmental Protection Agency).

Generators of medical waste are responsible for the waste in what is referred to as “cradle to grave.” The generators must comply with all laws from the moment the waste is generated through each step of handling, storing, transportation, and ultimately rendering the waste harmless. Lack of compliance cause fines from multiple agencies which can reach $12,600 per instance per day and higher.

Medical Waste Management Objectives

Medical waste management guidelines were established in the 1980s when there were increased cases of potentially infectious healthcare waste exposed in the environment. What began as the Resource Conservation and Recovery Act and Medical Waste Tracking Act has expanded so that state and federal government officials can monitor, track, and get confirmed approval of the safe handling and destruction of medical waste. The objective of all of the regulations is to create a controlled waste stream that complies with all laws so that people, animals, the community, and the environment are safe from transmission of dangerous diseases. Any organization or company that doesn’t comply with the laws can face fines from multiple agencies. Following best practices, any healthcare organization or facility that generates medical waste can help to assure that they are complying with the laws and keeping individuals and the environment safe.

“The Occupational Safety and Health Administration plays a major role for compliance”

Medical Waste Defined

There are a variety of items that can be classified as medical waste and it includes both hazardous and non-hazardous waste. Medical waste can be generated from hospitals, physician offices, dentists, veterinarians, laboratories, coroners, funeral homes, nursing homes, medical research facilities, and blood banks. The waste generally relates to any material exposed or contaminated with blood, body fluids, or any other potentially infectious materials. Other names for medical waste is biohazardous waste, clinical waste, biomedical waste, OPIM (other potentially infectious materials), or PIMW (potentially infectious medical waste).

Regulated medical wastes are divide into specific categories:

Regulated Medical Waste; OSHA Definition

The Occupational Safety and Health Administration plays a major role for compliance of local, state, and federal laws. OSHA’s definition of medical waste via its Bloodborne Pathogens Standard (BBP) offers the definition in 29 CFR 1910.1030 as:

“A liquid or semi-liquid or other potentially infectious material; contaminated items that would release blood or other potentially infectious materials in a liquid or semi-liquid state if compressed; items that are caked with dried blood or other potentially infectious materials and are capable of releasing these materials during handling; contaminated sharps; and pathological and microbiological waste containing blood or other potentially infectious materials.”

Additional, OPIM (Other potentially infectious materials) which are also required to be collected, treated, and disposed of as regulated medical waste is defined as:

“The following human body fluids: semen, vaginal secretions, cerebrospinal fluid, synovial fluid, pleural fluid, pericardial fluid, peritoneal fluid, amniotic fluid, saliva in dental procedures, and body fluids that is visibly contaminated with blood, and all body fluids in situation where it is difficult or impossible to differentiate between body fluids; (2) Any unfixed tissue or organ (other than intact skin) from a human (living or dead); and (3) HIVcontaining cell or tissue cultures, organ cultures, and HIV- or HBV-containing culture medium or other solutions; and blood, organs, or other tissues from experimental animals infected with HIV or HBV.”

There are some areas of uncertainty as OSHA considers “saturation” as the defining characteristic between non-regulated and regulated medical waste. It’s always a better idea to err on the side of caution and discard all blood contaminated wastes as regulated medical waste.

Identifying What Isn’t Regulated Medical Waste:

There are many items that are generated in the healthcare field that aren’t considered as medical waste. In fact, a majority of items fall into this category and don’t require special management. Some items that aren’t medical waste include but are not limited to:

Complying With Medical Waste Laws/Guidelines

The goal of medical waste compliancy is for the promotion of safety for people who manage the waste, those that come into contact with the waste, for the community and the environment. Good practices for waste management will minimize the potential exposure for hazardous transmittable diseases.

Containers for regulated medical waste are to be rigid, sturdy, leak-proof, puncture-proof and can be sealed securely. The containers are designed to allow transport, minimizing exposure for everyone if an accident or breach occurs. Wherever possible, try to make use of containers that are resuseable which reduces impacts on the environment as well as cost.

Sharps waste is required to be discarded in a puncture-proof, OSHA-approved container. Any blood contaminated or saturated items should go into a red bag or medical waste container. The red bag should be filled ¾ full for sharps to avoid accidents and should be wrap-tied or sealed shut. Loose sharps should never be placed into a medical waste container.

Pharmaceutical waste should be placed in a blue or black container prior to disposal. Pharmaceuticals should never be dumped into the sewer.

What to put in a red bag: contaminated gloves, gauze, bandages, PPE, blood saturated items, blood and OIPM, bodily fluids, sealed sharps containers, pathological waste, trace chemo waste.

What to NOT put in a red bag: non-infectious garbage, any type of medication, fluid, pill or tab; loose sharps, compressed gas containers, radioactive waste, hazardous chemical waste, soiled linens.

Labels and Packaging

All containers, packaging and labels are required to meet the DOT (Department of Transportation) standards for testing strength (ASTM D 1709-01 and 165 gram dart test). Bags and containers that are filled should be sealed and stored in a safe location that is only accessible by authorized personnel.

Labeling of medical wastes that are generated is also required by DOT regulations. Before any medical waste can be transported it must be identified with the appropriate label by the generator. It should include the name, address, phone number and date of the generator. If there are multiple red bags or sharps containers that have been consolidated into a large container the same information must be placed on the outside of the packaging. Any/all pathological, pharmaceutical, or chemotherapy wastes must be separately packaged from those that are categorized as general biomedical wastes (sharps and red bag wastes), as well as marked clearly for appropriate treatment and management requirements.

Storage and Collection

Storage of all containers are required to be in containers that are:

Most generators coordinate with a professional, licensed and trained medical waste management company for the collection, transport, and disposal of medical waste. In some cases, certain healthcare organizations have in-house disposal that require licensed and trained staff for rendering the medical waste harmless.

Facility Health and Safety Requirements for Individuals

OSHA’s (Occupational Safety and Health Administration) BBP (Bloodborne Pathogens Standard) has a variety of requirements for staff/volunteers that include full communication for many of the areas of medical waste such as labeling, storage, and containment. The BBP specifically sets requirements for a facility to:

Health and safety training should include full compliance with all regulatory conditions. Generators should also establish procedures for compliance training, incident reporting, SDS management, OSHA safety audits. Additional training recommended should include HIPAA (Health Insurance Portability and Accountability Act) and DOT regulatory requirements.

The Importance of Waste Manifests

All generators are responsible for the medical waste that they generate and ensuring that the waste is transitioned into non-harmful waste before disposal. Laws require that the generator not only have and maintain all documentation of the waste management stream, but that they have the documents and certificates available at any time for audit or tracking.

Every internal person that has taken possession of the waste must sign the manifest prior to it being removed from the facility. Each internal individual at the facility that is subjected to the waste must take the HM-181 hazardous waste training. 

Each medical waste load that is shipped for destruction off-site should be able to be tracked with a manifest from start to finish. All professional, licensed and trained medical waste management companies will supply a manifest for every load that they pickup.

The waste manifest is the chain of proof for generators to demonstrate compliance with all laws and guidelines. Without full documentation, a generator may be subject to fines by multiple agencies.

Emergency Procedures in Case of Leak or Breach

Generators should have full documentation on the methods and steps to take in case of a medical waste leak or breach. There should be a chain of contact command for staff to supervisors/managers and managers to external organizations that may need to be contacted.

Staff should be educated on emergency actions to take to assist in cleaning/resolving the leak or breach for personal exposure. Equipment and supplies should be readily available for the actions needs and should be regularly review to ensure that they are complete and functioning.

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