A Comprehensive Guide to Medical Waste
The EPA defines medical waste as "healthcare waste that may be contaminated by blood, body fluids or other potentially infectious materials and is often referred to as regulated medical waste." Even though medical waste is critical, proper handling and disposal can be overlooked by medical practices because, let's face it, managing medical waste is complicated. There are numerous federal and state regulations that your medical practice has to abide by, and scouring complex regulations is not something most medical offices have time to do. We created this comprehensive guide to provide you with best practices that will help safeguard your office.
Proper medical waste management is essential for ensuring the safety of your medical practice and the environment. It is critical that you and your staff follow proper separation, storage, handling, and packaging waste guidelines. We have created this comprehensive guide to help make your job easier. Please bookmark this resource or download the full ebook for easy reference when evaluating your medical waste processes.
Types of Medical Waste
Regulated medical waste is a catch-all term that covers the items that fall under federal and state disposal regulations. Some regions call this material biomedical waste or infectious waste. Federal laws that define and regulate hazardous and non-hazardous solid waste include the Resource Conservation and Recovery Act (RCRA) and the Code of Federal Regulations. Each state also provides its own definition of the regulated medical waste covered by its laws.
While the details vary between regions, you typically see these five major categories:
1. Biohazardous Waste
This type of waste is commonly found in medical offices and hospitals. It includes blood, blood products, body fluid spill cleanup materials, dialyzers and tubing, saturated or soiled disposable items, small pathology waste, tissues, and anything contaminated with biohazardous waste that is not classified as sharps waste.
2. Biological Waste
Most commonly generated in laboratories, biological waste includes materials such as bacteria cultures, live and attenuated vaccines, culture dishes, and any devices that come in contact with such waste.
3. Contaminated Sharps Waste
This category includes blades, broken glass, glass pipettes, microscope slides, needles, razors, scalpels, staples, syringes, tubes, wires, and any contaminated item that is sharp and could puncture a bag.
4. Pathology Waste
The tissue samples from tests and biological matter removed during surgery are examples of pathology waste. Anything that was once a part of an animal or a human goes into this category. Pathological waste should be packaged and labeled for incineration.
5. Pharmaceutical Waste
Pharmaceutical waste is any pharmaceutical product that is designated for disposal, no longer used as intended, or unable to be returned to the manufacturer.
Pharmaceutical waste is either hazardous or non-hazardous. Hazardous waste can be divided into three primary categories: listed pharmaceutical waste (RCRA), chemotherapy waste (bulk), and controlled substances.
Listed Pharmaceutical Waste
Listed black-container waste is on one of the four hazardous waste lists by the RCRA. The P-list and the U-list pertain to hazardous waste pharmaceuticals, which also include commercial chemical products. The D-list covers waste products that are not strictly pharmaceutical, but exhibit hazardous properties that make them flammable, corrosive, toxic, or highly reactive.
Chemotherapy waste is technically a pharmaceutical waste that is covered as a single category in legal terms. However, the medical disposal industry breaks it into two sub-categories:
- Bulk chemotherapy waste: This category includes any product that is a characteristic waste, listed, and still contains more than 3% by weight of the regulated ingredient. Examples include IV bags leftover after treatment and materials used to clean up chemotherapy spills.
- Trace chemotherapy waste: This category includes intact and unused EPA "listed" or "characteristic" chemotherapy waste that is less than 3% by weight of the ingredient (RCRA Empty). It also consists of any items that come into contact with hazardous substances, such as rubber gloves and gowns.
Controlled Substance Waste
Controlled substances are divided into five schedules as determined by the Drug Enforcement Administration. To be properly discarded, they must be “destroyed beyond reclamation” with two healthcare professionals documenting the process. Incineration is the preferred method.
Disposal of controlled substances is tightly regulated, regardless of their hazardous qualities under the RCRA.
Medical Waste Containers
Make sure your staff knows exactly what kinds of medical waste your practice produces and how to separate and store each type of waste stream to keep the medical waste disposal process running smoothly and stay in compliance. Proper collection and segregation can help guarantee that you do not mix medical waste into the wrong stream or fail to comply with state or federal guidelines and regulations.
Don’t store your waste too long! Be sure you have your waste service provider on a monthly scheduled pickup. If your practice generates less than 220 lbs a month, it is best practice to have your medical waste picked up every 30 days to decrease your employees' risk of contamination.
Here is a handy list for quick reference to make the process smooth for your medical practice.
What Goes in the Red Sharps Container
- Needles and syringes
- Blades and lancets
- Razors and scalpels
- Broken glass
- Glass pipettes and tubes
- Microscope slides
- Staples and wires
- Disposable suture sets
Bottom Line: Any other contaminated sharp items
What Goes in the Red Biohazard Bags
- Blood, blood products, and other potentially infectious material
- Saturated or soiled disposable items such as gauze, dressings, gloves, and clothing
- Containers, catheters or tubes with blood or blood products
- Dialyzers and tubing
- Tissues and small pathology waste
- Used culture plates, tubes, bottles, and devices
- Blood and body fluid spill cleanup materials
Bottom Line: Anything contaminated with biohazardous waste that does not go in a sharps container
What Goes in the Yellow Trace Chemo Container
Trace contaminated chemotherapy is waste generated in the preparation and administration of antineoplastic/cytotoxic drugs.
- IV tubing
- Empty bags/bottles
- Empty drug vials
Bottom Line: All trace chemotherapy waste
What Goes in the Black RCRA Hazardous Waste Container
- Certain pharmaceuticals (D, U, or P Listed)
- Antineoplastic waste
- Radioactive waste
- Mercury-filled devices, batteries, blood pressure cuffs & gauges, thermometers
- Chemicals such as xylene, formaldehyde, formalin, acetone, toluene, mercury, fixatives, and alcohol
- Disinfectants & chemical sterilizing agents
Bottom Line: All RCRA hazardous waste
What Goes in the Blue or Green Non-Hazardous Pharmaceutical Container
- Pills, antibiotics, and injectables.
Bottom Line: All categories of pharmaceuticals, not D, U or P Listed
Proper Labeling and Storage
Labeling Medical Waste Containers
Container labeling seems like a relatively easy task; however, label coding is a critical step in the medical waste disposal process. You need to make sure to use the correct typography, color, and type of ink.
According to Alabama’s guidelines for medical waste disposal, containers must have the International Biological Hazard Symbol and be labeled with one of the following words:
- Medical Waste
If the container does not have a red background color, then red lettering with a contrasting background color should be used. The ink has to be indelible and considered permanent if exposed to the environment under normal weather conditions. Finally, the wording should be either printed on the container or a securely attached label, on two or more sides.
Also, the outermost layer of packaging (if smaller containers have been used) has to include the following information:
- Name and address
- Date the waste was packaged in the outermost container
Find out even more specifics on how to properly label your medical waste containers with our helpful guide to medical waste labels.
Storing Waste for Pickup
Once your medical waste has been properly segregated, it may need to be stored until pickup. (Note: Placing waste in a container at the point of generation, such as an examining room, would not be considered as storage.) For medical facilities that generate more than 220 pounds of medical waste per month, storage must not exceed seven calendar days from the date that initial storage, unless the waste is refrigerated at a temperature less than 45 degrees Fahrenheit.
- A secure area that is inaccessible to the general public
- An area that is separated from food consumption areas
- A refrigerator or freezer that can be used, if necessary
What Happens to Medical Waste
It’s important to remember that you are still liable for your waste after it leaves your office. Pickup and transportation is just one part of the process. Be sure you have your waste service provider on a monthly scheduled pickup. It is best practice to have your medical waste picked up every 30 days to decrease your employees' risk of contamination from said waste if your practice generates less than 220 lbs a month.
Questions to Consider:
- After the medical waste leaves your practice, do you know exactly where it goes and how long it takes to get to a treatment facility?
- Where is the treatment facility; is it in the same state?
- What does the inside of your waste provider’s truck look like?
- Does the waste cross state lines?
- Once the waste reaches a facility, how long does it stay there? Is it treated at that facility?
- How is the waste treated and who treats it?
- When the treated waste leaves, where is its final destination?
After Leaving Your Office
All medical waste must be safely and securely transported to a treatment or disposal facility. There are strict guidelines for transporting the waste, including segregating different types of waste inside the truck. Also, procedures are in place in the event of an accident, allowing for spill containment and cleanup, if necessary. Did you know that each vehicle is required to carry a written contingency plan for spills and accidents, as well as the tools and materials needed to implement the plan? Such measures are taken to protect the waste handlers, the public, and the environment from exposure to the potentially infectious waste.
There are also stringent requirements set forth by the U.S. Department of Transportation (DOT) for the vehicles themselves, including items such as keeping the vehicle in good repair and frequently cleaning it and ensuring the overall durability of the vehicle.
Your waste manifest form should include the route your waste will take, which is an item to look at closely. Some medical waste disposal providers may have a big geographic footprint, which means they transport waste across state lines. They may transport your waste long distances for either treatment or final disposal. Providers who have their own treatment facilities may have a smaller footprint. Plus, if the facility is nearby, that is an added bonus. Less time on the road means reduced risk for you, the waste generator.
Ideally, your waste services provider should use dispatch software that allows them to pinpoint the location of your waste at any time. Vehicle routing and mapping technology is key to providing safe, efficient transportation.
Arrival at Treatment Facility
Once the waste arrives at a treatment or disposal facility, it must be carefully unloaded to avoid damaging the containers or spilling their contents. All manifests that have accompanied the waste must be signed by the next person who handles the waste. Medical waste requires some form of treatment before it’s disposed. These treatments aim to deactivate or destroy harmful substances, pathogens, and chemicals. While some larger medical facilities can afford their own equipment for handling these tasks, most prefer to partner with a fully certified medical waste management provider, who handles the expense and expertise necessary to maintain compliant treatment facilities.
In performing the proper destruction and deactivation of your medical waste, waste management providers use one of these four techniques: autoclaving, chemical disinfection, microwaving, or incineration.
Transported to Final Disposal
After your medical waste has been treated, it must be disposed of properly, with accurate documentation (certificate of destruction) of the process. It is best practice for this process to be completed within one day. Again, the less time your waste is on the road, the less risk for you. It is more beneficial for you to be located close to the waste treatment facility. Are you aware of the “final resting place” of your waste? If not, find out to see if you can reduce your liability and geographical footprint by using a local service.
Documentation to Request from Your Waste Provider
You are responsible for medical waste even after it leaves your facility. Any permits required for the transport and delivery of your medical waste should be kept on file, and you should know where your medical waste is going. Make sure the medical waste transporter identifies your medical waste by labeling each container with your facility's name so it can be identified at any time during transport. Be sure to receive a signed manifest document from your medical waste services provider before the waste leaves your facility. This is the most important part of the transportation process. Finally, you should receive a certificate of destruction from your medical waste transporter after the medical waste is rendered non-infectious or destroyed and disposed.