Regulated Medical Waste: An Overview
Medical waste is generated by many types of organizations, including but not limited to hospitals, medical clinics, physician’s offices, veterinary clinics and hospitals, blood banks, dental practices, coroner’s offices, funeral homes, tattoo parlors, laboratories, and medical research facilities. Regulated medical waste (RMW) is a subset of waste types that may be contaminated by blood, bodily fluids or any other infectious materials that could cause harm to humans, the community and/or the environment.
While there are many federal agencies that act to regulate laws and guidelines for the storage, transport, and disposal of RMW, each state has its own rules that must be complied with, in addition to or superseding some of the federal guidelines. Individual states also have differences in the accepted definitions of RMW and almost all states have adopted the DOT (Department of Transportation) rules for storage, transport, and disposal of RMW.
Types of Regulated Medical Waste
A majority of states have accepted six defined types of regulated medical waste:
- Pathological waste can be organs, body parts, tissues, and all body fluids that are removed during autopsy and surgery.
- Human blood and blood products can include but are not limited to waste blood, plasma, serum, and any blood products.
- Cultures and stocks of infectious agents, also known as “microbiological waste,” can include but are not limited to specimens from pathology and medical laboratories, including devices and culture dishes used to inoculate, mix, and transfer, and may also incorporate both attenuated and live vaccines that have been discarded.
- Sharps that have been contaminated can include but are not limited to hypodermic needles, scalpels, blades, broken glass, Pasteur pipettes, and any contaminated item that can pierce the skin.
- Isolation waste is created by hospital patients that have been isolated as a precaution and protection for others from communicable diseases.
- Animal carcasses, bedding, and body parts that have been contaminated to pathogens in biologicals production, research or in vivo testing within the pharmaceutical arena.
Organizations that Regulate
In the past, the EPA (Environmental Protection Agency) took control of regulating all medical waste. Currently, each state has adopted compliancy guidelines and laws and are responsible for establishing and enforcing the regulation of all medical waste generated in any facility type. States have established a “cradle-to-grave” regulation compliancy which means that the organization generating the medical waste is responsible for obeying all laws for handling, storage, transport and disposal. A majority of the states have created their guidelines based on the federal laws, however, there are some that have created their own laws which may not resemble the historical federal laws. In almost all states, the primary responsibility for development and enforcement of medical waste management and disposal is the environmental protection agency for that state. In some states, the department of health may also participate and possibility serve instead of the state environmental protection agency. States have individual regulations regarding packaging, storing, and transporting medical waste. In some states there is a requirement of the organization generating the medical waste to register and/or get a permit, on-site training, waste tracking, on-site treatment, reporting, develop contingency plans, and recordkeeping.
OSHA (Occupational Safety and Health Administration) can be either federal or state organized, and they regulate several factors involving medical waste which can include but are not limited to such things as sharps management, container requirements for storage of medical waste, medical waste containers/bags labeling, and employee training. The purpose of OSHA involvement is to protect staff, community, and the environment from possible bloodborne pathogen exposure.
Environmental Protection Agency (EPA) does have compliancy regulations regarding the emissions that are generated from the incinerators that are in-house in hospital/medical/infectious waste locations and laws/guidelines regarding FIFRA (Federal Insecticide, Fungicide and Rodenticide Act) for specific medical waste treatment methods that use chemicals for treatment.
Department of Transportation (DOT) guidelines are for those companies that transport hazardous materials including RMW, rather than the generators of RMW. Since those that generate RMW are responsible for the final disposal, knowledge of the DOT rules is always suggested.
CDC (Centers for Disease Control) is another federal organization that has a set of guidelines for control of infection.