Cradle-to-Grave: You’re Responsible, But What Does That Mean?

Generally, medical waste is healthcare waste that may be contaminated by blood, body fluids or other potentially infectious materials. Often referred to as regulated medical waste (RMW), this type of waste is primarily regulated by state environmental and health departments. Have you heard the term “cradle-to-grave” used in reference to medical waste regulations? It’s an important aspect of the medical waste disposal process. You need to know exactly what the provision means for your medical practice.

Where Does the Term “Cradle-to-Grave” Come From?

The term “cradle-to-grave” comes from the Resource Conservation and Recovery Act of 1976 (RCRA), which was established to set up a framework for the proper management of hazardous waste. RCRA is the legislation that authorized the United States Environmental Protection Agency (EPA) to draft regulations to realize the goals of RCRA.

EPA developed a comprehensive program to ensure that hazardous waste is managed safely from the moment it is generated to its final disposal (cradle-to-grave). Compliance with requirements is enforced by EPA and the states, who may implement key provisions of hazardous waste requirements with an approved state program. In Alabama, the Alabama Department of Environmental Management’s (ADEM) Land Division administers the major provisions of federal hazardous waste laws, specifying environmental standards for hazardous waste generators and transporters, and treatment, storage, and disposal facilities. ADEM’s medical waste program follows the cradle-to-grave regulatory approach and tracks waste from generation to final disposition, imposing standards at each step to safeguard the environment. What does this mean for your medical practice? Legally, you maintain ownership of your medical waste.

Signed, Sealed, Delivered . . . It’s Still Yours

You correctly sorted and collected your medical waste. Appropriate containers were used and you sealed and labeled them properly. Finally, you signed and received the proper documentation from your medical waste disposal company, and the waste was delivered to a treatment facility. Your work is done and you are off the hook as far as responsibility for your medical practice’s waste, right? Wrong.

From the moment your medical practice generates medical waste, the disposal of that waste is ultimately your responsibility. Even if you hire a medical waste disposal company to transport and dispose of your waste, you are still liable for any failure on their part to follow the law.

Your waste disposal company should  have their name and contact information on all containers and each dedicated RMW load or individual containers within a mixed load will have a manifest that includes:

• Date of receipt
• Name, address, and telephone number of the waste generator, waste transporter, and waste treatment facility
• Dated signature of each of the above (Generator, Transporter, and Disposal Facility)

Each individual container should be documented to insure cradle-to-grave destruction. However, medical waste violations or accidents can happen along the way. For example, things like missing documentation, missing labels, or open containers can result in hefty fines for you, the waste generator.

It’s important to remember that if an incident happens to occur at any point during your waste’s lifecycle, you will be held liable. This means that you could be obligated to pay costs associated with any cleanup or penalties. There is no expiration date and no time limit on your responsibility, which extends through the entire waste disposal process, even including final destruction.

When is My Medical Waste Considered Harmless?

The waste is your liability until it is rendered harmless and can be recycled or thrown away. The sterilization process for RMW is usually done through the use of an autoclave, which steams items at an intensely high temperature where no bacteria can survive. After the autoclave process has removed the bacteria, the medical waste can be disposed of in the normal manner.

Written certification that all treatment requirements have been met is required. This includes a signed manifest provided by your waste services provider upon pickup and a certificate of destruction that is provided to you by your medical waste transporter after the medical waste is rendered non-infectious or destroyed and disposed. As a waste generator, you are required to visit the facility where your RMW is being treated.

Legally, you maintain ownership of your medical waste throughout the waste disposal process. However, you can hire a trusted medical waste disposal company to handle your waste properly, safely, and securely. That way, you can protect the health and safety of your employees, patients, and the community while maintaining compliance under state and federal regulations. Cradle-to-grave responsibility can sound intimidating, but it’s easy if you have the right waste disposal services partner. Request a free consultation, and we can  work with you to design a custom, comprehensive program for your facility’s entire waste stream. Get started by clicking the button below.