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Although the Centers for Disease Control and Prevention (CDC) has determined that routine procedures can be used to manage medical waste generated in the treatment of COVID-19 patients, scrutiny of medical waste management in hospitals & clinics has predictably been amplified by the COVID-19 pandemic.
This brings to fore a number of challenges, as regulated medical waste (RMW) is typically legislated at state rather than federal level.
For example, while virtually all states have enacted medical waste management regulations, standards vary significantly across them. In most cases, medical waste disposal rules resemble the Medical Waste Tracking Act of 1988. In other states, not so much.
Further complicating matters, rules for medical waste disposal are often written and enforced by more than one state agency. Consider:
In most states, the EPA is responsible for developing and enforcing regulations for medical waste management. But in some, the Department of Health is involved (e.g., Missouri and Oklahoma) or might even be the primary enforcer (e.g., Colorado)
01 / More than one federal agency regulates medical waste management
Adding to regulatory complication are at least five different federal bureaucracies:
OSHA. The final disposal of RMW isn’t regulated by OSHA. But as RMW is most dangerous where it’s generated, it’s deemed an occupational safety hazard in the agency’s purview; and OSHA guidelines supersede state & local ones if the latter are less strict.
DOT. As RMW logically requires hazardous waste management, its movement by road, air, rail, or waterway is subject to applicable DOT rules for transporting hazmat.
CDC. The CDC propagates and enforces specific guidelines for medical waste management in the interest of infection control.
EPA. Companies proffering products claiming to reduce RMW infectiousness must register them with the EPA.
DEA. Regulates how hospitals & clinics with onsite pharmacies must manage their collection receptacles or voluntary mail-back programs for spent, expired, or unused RMW.
02 / How do you know if you have RMW to dispose of?
Any waste stream that contains blood, body fluids, or other potentially infectious materials is considered an RMW, also known as “biomedical” or “infectious medical” waste. And although there are some guidelines, there is no explicit definition of RMW in federal law.
Individual state authorities dictate which wastes are RMWs or require special handling. You can get some idea about which states say what regarding medical waste management here.
But in short, your hospital or clinic throwaways require medical waste management if they include:
Anything carcinogenic, teratogenic, or mutagenic
Something that’s been soaked in blood (gloves, gauze, gowns, etc.)
Materials from decommissioned medical equipment (e.g. batteries and heavy metals)
Cultures of infectious diseases and/or agents
Unused or otherwise discarded vaccines, antibiotics, pills, and other pharmaceuticals
Laboratory disinfectants and solvents
Human or animal tissues
Wastes from the rooms of patients having communicable diseases
03 / Best Practices for Handling Medical Waste
Anyone who handles RMW—whether incidentally or as part of his or her job should be trained in safe work-practices. Among them:
Identify biohazardous wastes, separating each into appropriate containers for sharps, pharmaceutical, chemical, pathological, and non-hazardous categories.
Do not mix hazardous and non-hazardous wastes (as you’ll wind up overspending on medical waste disposal).
Only use approved containers for a particular category of waste, such as special tubs, puncture-proof containers, and/or certified cardboard boxes.
Use the medical waste disposal color code (see below).
Specify a secure dry area to store containers for scheduled pickup and/or shipping.
Observe DOT regulations and weight restrictions for labeling and packaging.
Have correct documentation as required by state & local agencies, the DOT, the EPA, and OSHA.
04 / How to dispose of regulated medical waste
Most states require RMW to be made non-infectious before it can be treated as nonhazardous solid waste. This could be done by burning. About 90 percent of biohazardous waste is incinerated. Other methods include chemical disinfection (e.g. chlorine treatments) and encapsulation (e.g. isolating sharps in special containers).
However, only the largest hospitals & clinics have the equipment to effect complete incineration: a process called autoclaving. Chlorine treatments can emit chloroform and other persistent toxins. And encapsulation isn’t a complete solution for most RMW.
This means you’re going to need to transport RMW offsite to a hazardous waste management facility; and thereby you’ll need to hire both a transporter and a treatment company, each licensed or “permitted” to handle RMW. You can find out more here.
05 / Medical Waste Color Code
One of the most important parts of medical waste management is proper color-coding, as each color specifies (or proscribes) one or another disposal process. These are:
Red bags for syringes (without needles), soiled gloves, catheters, IV tubes, etc.
Yellow bags for dressings, bandages, swabs with body fluids, blood bags, human anatomical waste, and body parts
Blue-marked cardboard boxes for glass vials, ampules, and similar glassware
White translucent puncture-proof containers for needles, blades, and other sharps
Black bags for “nonbiological” medical waste such as hospital stationery; leftover foods, peels, rinds, and other kitchen waste; medicine packaging; as well as disposable masks, caps, cups, shoe-covers, and cartons, and sweeping dust
The Upshot
The evolving strategies for the containment COVID-19 are creating unprecedented burdens for hospitals & clinics.
Because of its danger to public health, your medical waste management practices endure the scrutiny of more than one federal agency. Among these are the DOT, EPA, DEA, and OSHA—as well as those of different states & localities.
Thereby, regulatory hurdles for medical waste management are significantly more complicated than for any other kind of hazardous waste disposal. Such a challenge requires that you get expert advice to avoid any number of pitfalls—many of them litigable, and some even criminal.
You can trust MCF
For over 30 years, the hazardous waste consultants at MCF have been delivering comprehensive medical waste management services at the most competitive prices for hospitals & clinics, including pick-up, transportation, EPA-approved disposal, and more.
Email us today or call 866-315-8116 to learn more. And thank you for reading our blog!
Robert Losurdo
President, COO
