Efficient Disposal of Regulated Medical Waste (RMW) During Shifts in Volume

Table of Contents

1. What qualifies as regulated medical waste?
2. The flow of regulated medical waste
3. Sudden, extreme changes in demand flow
4. Importance of proper procedures
5. Proper segregation of waste
6. Don’t ignore risks
7. Who’s responsible?

In normal circumstances, U.S. hospitals produce more than five million tons of medical waste each year, or about 29 pounds from each staffed bed every day. Add in waste from other medical facilities, dental offices, pharmacies, veterinary clinics, funeral homes, and other medical waste generators, and that number is significantly higher. Regulated medical waste (RMW) makes up about five to 15 percent of a hospital’s total waste stream.

At times of higher demand, such as during a pandemic, the disposal of RMW becomes much more logistically complicated. What happens when there are sudden extreme changes in the flow of waste and, subsequently, a substantial increased (or decreased) flow of demand for RMW pickup, removal, and disposal? TriHaz Solutions has processes, procedures, and container inventory in place that make us flexible regarding sudden changes in RMW demand flow.

1. What is Regulated Medical Waste

Regulated medical waste includes:

• Microbiological specimens including vaccines, culture dishes, and other waste exposed to human pathogen agents.
• Pathological waste and certain body fluids.
• Sharps or any waste that may cause a puncture or cut.
• Absorbed or unabsorbed blood and blood products.
• Contaminated animal waste including bodies, parts, and bedding of animals exposed to human pathogens.
• Trace chemotherapy waste.
• Isolation waste from Biosafety Level 4 agents.
• Other waste designated as infectious or other materials that have come in contact with infectious waste.

RMW disposal is complex not only because of its volume but because it’s regulated by multiple local, state, and federal agencies, including, amongst others, the EPA, CDC, DOT, DEA, and OSHA. It’s also up to 100 times more costly to manage than municipal solid waste or recyclables.

2. The Flow of RMW

Management of the collection, transportation, and disposal of RMW is a serious undertaking at any time. Disruptions that come with extra pickups due to an increase in flow make it even more weighty, particularly when the large entities we serve require 18-wheelers to come in more frequently.

In recent months, TriHaz has been experiencing a 300% increase in service needs across all the facilities we serve. Sites we previously visited three times per week now require servicing every day. Facilities that, under normal circumstances, would have 50 red medical containers now have 150 of them in place. At one of our client sites, we’ve set up a 53-foot trailer where we perform a “drop and swap” twice a week.

Personal protective equipment (PPE) makes up a large percentage of the increased volume of RMW we’re seeing. The majority of the increase, though, is from isolation rooms and wings that hospitals and other medical facilities have created, with everything that comes out of these rooms having to go into RMW containers. Also, blood-contaminated items that typically would need to be saturated to be considered RMW are required to be included with other waste.

All the variables governing RMW management are amplified in times of extreme flow changes. Depending on the circumstances, there might be additional regulations put in place regarding the segregation, packaging, labeling, and storage of RMW. As an essential business, TriHaz has had to quickly adapt to the current increase in demand.

3. Sudden, Extreme Changes in Demand Flow

One of the most significant challenges hospitals and other facilities face during a time of increased demand flow is continuing to follow proper RMW disposal procedures. Many facilities find additional guidance and support helpful, and we are able to serve as a process consultant when needed.

To help make the process as smooth as possible, we made some key accommodations and adjustments to our regular procedures. For instance, one of our smaller customer facilities was normally scheduled for an RMW container pickup every three months. They now need four containers picked up every week. Numerous other accounts went from one or two containers per month to multiples per week. This was possible because TriHaz has the assets in place to meet requirements for increases such as container demand, larger vehicles for pick-ups, and other creative custom solutions.

To quickly adapt, we proactively responded:

• Established a second shift of employees.
• Invested in more containers, which have a two to three-week lead time.
• Found multiple PPE providers so our employees were protected.
• Invested in additional moving assets, such as trucks and trailers.

The result is a still-efficient process that meets customer demand and complies with applicable regulatory requirements.

4. Importance of Proper RMW Disposal Procedures

The improper management of RMW disposal poses a health risk to the public and a financial risk to medical waste generators. For instance, improperly discarded needles and other sharps can expose staff to injuries and potentially serious infections.

Unfortunately, RMW management is not a one-size-fits-all solution. Different types of RMWs have distinct regulations and requirements for their disposal. The goal of all RMW proper procedures should be:

• Optimization of waste
• Compliance and education
• Position and movement
• Storage optimization

5. Proper Segregation of Waste

Proper segregation of waste is even more crucial during times of high demand. It increases employee and patient safety, reduces the risk of exposure to blood-borne pathogens, and mitigates medical facility-acquired infections. Facilities can ensure proper segregation by understanding the waste segregation trail and adopting policies and procedures that regulate the handling of RMW.

For hospitals and other RMW generating businesses who are unsure if their facility’s waste management plan is sufficient and compliant, a waste audit can help. TriHaz offers a free consultation that assesses your current processes and procedures and helps you create a custom, comprehensive program that includes waste reduction and cost savings opportunities.

5. Don’t Ignore Risks

It’s understandable that during times of high demand the immediate goal is to just get rid of the increased waste. But you can’t ignore the risks that come with not properly planning for RMW disposal. Anything that helps your facility reduce its risk is ultimately beneficial to you.

Here’s how to reduce risk at every stage of the collection, transportation, and disposal process.

• Collection. By reducing the number of vendors who are in and out of your facility, you can reduce costs, protect employees and patients, and mitigate damages. TriHaz offers bundled services that can include medical waste, pharmaceutical waste, and hazardous waste pickup and disposal, as well as document destruction and online compliance training. Instead of four vendors, four trucks, and four visits to your facility, all your medical waste disposal needs are met with our bundled services.
• Transportation. “Out of sight, out of mind” is not a good mindset for RMW generators. TriHaz offers a flexible schedule that fits your facility’s specific needs. Our cradle-to-grave touchpoint process ensures your waste is on the road when it should be, which mitigates risk exposure. We also have the permits necessary to properly handle, treat, and dispose of your RMW and other waste streams. Other companies may say they have the right permits, but you need to make sure those permits cover your location and meet your state’s requirements.
• Disposal. Our state-of-the-art Huntsville, AL medical waste treatment facility meets and exceeds the EPA’s and state environmental agencies’ disinfection regulations and standards. We also properly label and track all containers picked up, and supply the required manifests and certificates of destruction required by regulatory entities. RMW generators must keep these documents on file (easily stored in our convenient online portal) for a minimum of three years. Your risk of heavy fines is reduced, protecting your facility from tens if not hundreds of thousands of dollars in penalties.

As you look for ways to mitigate risks as much as possible, keep in mind you also want to work with a company that’s big enough and prepared to handle increases in the flow of demand for RMW. For instance, smaller companies often have a minimal number of employees. If one or more of them becomes ill or is otherwise unable to meet your increased needs, you could face a serious disposal backlog. TriHaz has the assets, protocols, and disaster preparedness processes in place to handle increased demand.

7. Who’s Responsible for Improper Waste and Document Disposal?

RMW generators are ultimately and permanently responsible for the waste they dispose of, even decades after the fact. There is no expiration date on your responsibility.

DOT labels medical waste generators as shippers, which means your “package” of RMW must be “ready to go” before it’s picked up, transported, and disposed of by a waste management service provider like TriHaz. Non-compliance with DOT regulations can result in hefty fines of $1500 per container, per day, which goes back to the RMW generator.

It is incumbent on a generator to ensure its RMW is being treated and disposed of properly. If an improper disposal can be traced back to the generator, they will be prosecuted. In a recent case that lasted nearly seven years, Walgreens was ordered to pay the City of Los Angeles and 44 other local jurisdictions $3.5 million for its mishandling of customer records and improper waste disposal. The company’s stores are also now subject to periodic inspections and audits.

We’re Here to Make Sure You Get it Right

Many RMW generators we talk to in the Greater Tennessee Valley area are surprised to learn they’re entirely responsible for the waste they generate from “cradle to grave” and beyond. To make sure your facility is compliant, TriHaz offers convenient, free online training. Our online portal offers over 100 training videos and modules designed to help keep your employees safe and your facility protected against possible fines. Once a course is successfully completed, your facility can print out a certification that can be kept on file.

To learn more about the rules, standards, and steps involved in keeping your facility compliant and safe during sudden and extreme changes in the demand flow for RMW, get in touch with TriHaz today.