/ IN THIS BLOG
Per the EPA, any waste stream containing blood, body fluids, or other potentially infectious materials is a “regulated medical waste.” But among professionals toiling in hospitals & clinics, the labels biowaste, biohazard waste, or biomedical waste roll off the tongue more readily. You’ll also hear hospital waste or infectious medical waste.
In any event, whatever it’s called, if you’re unsure whether or not one of your waste streams qualifies as an RMW, don’t take chances: get expert advice. The pecuniary penalties for mishandling biowaste, biohazard waste, or biomedical waste are substantial, not to mention a major distraction from your commitment to cure people and keep them healthy.
01 / Discerning what qualifies as biowaste, biohazard waste, biomedical waste, etc.
Some wastes are intuitively RMWs (regulated medical wastes): it would be difficult to plead ignorance if they were to appear in your general trash stream. Among them:
Cultures of infectious diseases and/or agents
Sharps (E.g., needles, scalpels, and lancets) (Learn more in this document)
Anything soaked in blood, like gloves, gauze, and gowns (Learn more in this document)
Human body tissues (Learn more in this document)
Animal body tissues (Learn more in this document)
Human body fluids (Learn more in this document)
Wastes from rooms of patients having communicable diseases
Something containing environmentally-restricted molecules or organisms
Multi-hazardous substances, so-called because they contain some combination of noxious elements wherein neutralizing one can make the other more dangerous (E.g. tissue samples preserved in formalin).
For more information about EPA identification numbers, your potential status as a generator, and what this all means for your business, please contact a representative of MCF Environmental Services, a full service hazardous waste management company.
However, some RMWs are not so obvious. Consider:
Materials from decommissioned medical equipment, like batteries and heavy metals
Discarded vaccines, antibiotics, pills, or other pharmaceuticals
Medical or laboratory packaging, unused bandages, or infusion kits
Laboratory disinfectants and solvents
Something some local authority deems carcinogenic, teratogenic, or mutagenic whereas most don’t (Think: State of California)
02 / Waste streams that commonly sit under the term ‘biohazard’ or ‘biomedical’ waste
Human blood and blood products. Anything contaminated with human blood is considered an RMW, biowaste, biohazard waste, or biomedical waste. So too is anything contaminated with blood constituents, such as serum or plasma, whether in liquid or semi-liquid form. Also bear in mind that any discarded substance is considered an RMW if it harbors the potential to release blood or blood products when compressed—whether in a liquid or semi-liquid form.
Human body fluids. These are considered RMWs, biowastes, biohazard wastes, or biomedical wastes whether in liquid or semi-liquid states. They include but are not necessarily limited to semen, vaginal secretions, cerebral spinal fluid, synovial fluid, pleural fluid, pericardial fluid, peritoneal fluid, amniotic fluid, and saliva.
Microbiological wastes. Any laboratory wastes containing any infectious agents in concentrated form are considered RMWs, biowastes, biohazard wastes, or biomedical wastes. Examples are specimen cultures; etiologic agents; live and attenuated viruses; blood or body fluids known to contain infectious pathogens; wastes from biologicals & serums production; and discarded culture dishes or devices used to inoculate, transfer, or mix cultures.
Pathological wastes. Tissues, organs, body parts, and any unfixed human tissue (except skin) are considered RMWs, biowastes, biohazard wastes, or biomedical wastes. These involve biopsy materials, tissues, and anatomical parts, whether from autopsies, procedures, or surgeries. surgery, procedures, or autopsy.
Animal wastes. Any animal carcasses or body parts infected or inoculated with human pathogenic microorganisms are considered RMWs, biowastes, biohazard wastes, or biomedical wastes. This includes any bedding material from animals so affected.
Sharps. These are always considered an RMW, biowaste, biohazard waste, or biomedical waste because—contaminated or not—sharps are patently dangerous if not effectively contained when discarded.
03 / Hospital & clinic responsibilities regarding RMWs
Your hospital or clinic must legally ensure that any & all RMWs, biowastes, biohazard wastes, or biomedical wastes are correctly treated and disposed of. This necessarily includes their proper packaging and transportation offsite to a legally “permitted” or licensed treatment, storage, or disposal facility.
Regarding packaging. State and local requirements for segregating, packaging, and labeling RMW will differ according to where your hospital or clinic is located; and state requirements are generally in excess of federal ones. Such differences across venues are another reason why you should get expert advice about managing RMW. But in sum, you must have systems in place for identifying & classifying RMW. And while each state has its own peculiarities, all of them nod to the OSHA Bloodborne Pathogens Standard.
Regarding transportation. Any entity that transports toxic material must be properly “permitted” and licensed to do so. For the vast majority of hospitals & clinics, this means contracting a reputable company to transit RMW offsite to a treatment, storage, or disposal facility. Such waste must be accompanied by a specialized bill of lading, called a hazardous waste manifest. Other paperwork might be required, such as a land disposal restriction form. If required documentation is inaccurate or missing, legal culpability lies with your hospital or clinic—not the transporter.
04 / The Upshot
In many ways, RMWs, biowastes, biohazard wastes, or biomedical wastes—call them what you will—are arguably the epitome of hazardous waste. And the Resource Conservation and Recovery Act (RCRA) stipulates that any entity that generates a hazardous waste is legally responsible for it—from the metaphorical “cradle-to-grave.”
This includes not only its onsite hazardous waste management, but also its subsequent transportation to a properly “permitted” or licensed offsite storage, treatment, or disposal facility. In other words, once you’ve generated a hazardous waste, there’s no way to rid yourself of complete legal responsibility for it: there’s no passing the buck if something goes wrong.
Obviously, these circumstances make it imperative that you apply a comprehensive approach to your hazardous waste management relative to RMWs, biowastes, biohazard wastes, or biomedical wastes; one that addresses all four aspects of hazardous waste management: generation, treatment, storage, and disposal.
Such an approach is a complicated undertaking—and it’s unlikely your hospital or clinic coincidentally employs staff with the proper knowledge and credentials to address just one of these hazmat aspects safely & legally, let alone all four of them.
You need a business partner with the experience & expertise to help you develop & maintain a comprehensive system for managing your RMWs legally and safely.
You can trust and depend upon MCF Environmental Services
The experts at MCF Environmental Services offer decades of experience providing all-inclusive hazmat services to hospitals and clinics relative to RMWs, biowastes, biohazard wastes, or biomedical wastes—and at the most competitive prices.
Email us today or call 866-315-8116 to learn more. And thank you for reading our blog!
Robert Losurdo
President, COO
