By Nancy W. Teolis, J.D., BLR Legal Editor-Environmental
nteolis@blr.com
What is Regulated Medical Waste?
Regulated medical waste (RMW) from healthcare facilities may be known as biohazardous waste, biomedical waste or infectious medical waste that is contaminated by blood, body fluids or other potentially infectious materials that pose a risk of transmitting infection. Types of medical waste include:
- Human pathological wastes
- Blood, blood products and body fluids
- Cultures and stocks of infectious agents Infectious sharps
- Isolation wastes from patients with highly communicable diseases
- Contaminated animal waste
State/Federal Regulations
Generally, solid wastes mixed with medical wastes are regulated as medical waste at the state level by the state environmental protection agency and/or department of health. However, medical waste that is also a hazardous waste must be managed in accordance with state and federal hazardous waste rules. This report discusses medical waste requirements that are common to many states.
Resource: Mixed Medical Waste
On the federal level, the storage and management of medical waste is primarily regulated by OSHA bloodborne pathogens standards. DOT hazardous material transport rules, EPA hospital/medical/infectious waste incinerator rules, as well as certain medical waste treatment technologies under FIFRA also may apply.
Registration/Permits
State rules vary on requirements for registration. Some states do not have any registration process and some require registration based on the quantity of medical waste generated.
Management Plans
Many states require RMW generators to prepare a medical waste management plan that includes the type of medical waste generated, segregation, packaging, and labeling procedures for untreated medical waste, on-site treatment methods, storage facilities, and employee training. Transporters may also have to prepare a management plan for the medical waste they handle.
Resource: Medical Waste Facility Plan Checklist
Storage
Storage begins after a shipping container is prepared for shipment to a storage or treatment facility. Storage of untreated medical waste must comply with the following requirements:
- RMW must be kept separate from other wastes in an area that is designated and clearly labeled with the universal warning sign or the word “BIOHAZARD”
- The storage area must be ventilated and located to minimize exposure to the public and is accessible only to authorized personnel
- Floor drains must discharge to an approved sanitary sewer connection
- Spill kits are required by some states
- There are often no time limits for medical waste storage if the waste is maintained in a nonputrescent state, uses refrigeration, and controls vermin and insects (other state storage time limits may range from 7 to 90 days)
Treatment/Disposal
In most states, RMW must be treated before disposal. Such treatment can be performed on-site or off-site at a permitted treatment facility. Medical waste treated on-site to render it non-infectious is usually no longer considered infectious for handling and disposal purposes and in some cases, it may be mixed with and disposed of with ordinary waste when certain rules are followed. However, many states require that treated waste remain segregated and often written notification must accompany the treated waste to its disposal location.
All states allow healthcare facilities to treat regulated medical waste on-site when an approved method of treatment is used. Some states require permits or operating plans for the treatment units, while others only require air pollution permits for incineration units. Approved methods usually include incineration, steam sterilization (autoclaving), microwave sterilization, and chemical disinfection.
Transportation
In most states RMW transporters must have a medical waste transporter permit in order to pick up, transport, or deliver RMW. Small volumes of RMW may be transported without a permit in some states.
Knowing your specific state requirements for the RMW management is essential if you want to remain in compliance with applicable federal and state regulations.
I’d like to do a series of posts on how to reduce regulated medical wastes at your facility. Leave a comment or send me an e-mail and tell me what medical waste topics are most important to you.
Nancy W. Teolis, J.D., has been a Legal Editor for BLR’s environmental law publications since 1993, focusing primarily on underground storage tanks, pesticides, and hazardous waste-related requirements. Before joining BLR, she worked for the law firm Rudman & Winchell in Bangor, Maine, with an emphasis on asbestos exposure litigation. She received her law degree from Western New England University School of Law in Springfield, Massachusetts, and is a member of the Connecticut bar.