What Makes Regulated Medical Waste Disposal So Complex?

Regulated medical waste (RMW) can be up to 100 times more costly to manage than municipal solid waste or recyclables. Proper disposal of RMW is also a much more complex process—and not only because it’s highly regulated by multiple local, state, and federal agencies, including the EPA, DOT, and OSHA. The CDC and DEA also publish guidelines and rules for RMW handling.

Handling of RMW is a Complex Enterprise

There are several contributing factors to the complex nature of RMW disposal.

• Multiple entities and authorities regulate proper RMW management.
• There are seven types of RMW and many separate designations and subcategories that can vary by state.
• Sorting, packaging, and storage requirements differ according to the type of RMW and compliance regulations.

Non-compliance with regulations can result in steep fines, so getting educated and staying up-to-date on RMW handling requirements is a must for medical facilities.

Who Regulates Medical Waste?

Sometimes it seems the question should be, who doesn’t regulate medical waste? Primarily regulated by state environmental and other health departments, there are federal agencies that also have regulations and/or guidelines regarding the handling of RMW. They include the Centers for Disease Control (CDC), the U.S. Food and Drug Administration (FDA), Occupational Safety and Health Administration (OSHA), and potentially others.

The Department of Transportation (DOT) also regulates the transport of RMW and requires each facility, or shipper, to properly train employees in the proper packaging of RMW. Non-compliance with DOT regulations also comes with hefty fines, payable by the RMW generator.

Types of Regulated Medical Waste

The main types of RMW are:

1. Contaminated sharps or any waste that may cause a puncture or cut, such as needles, scalpels, and syringes with attached needles.
2. Pathological and anatomical waste such as tissue samples from tests and biological matter removed during surgery.
3. Microbiological specimens including vaccines, culture dishes, and other laboratory-generated waste exposed to human pathogen agents.
4. Blood and blood products, whether absorbed or non-absorbed.
5. Contaminated animal waste, including bodily fluids and body parts, and bedding of animals exposed to human pathogens. Sharps used in veterinary facilities are generally managed as sharps waste.
6. Trace chemotherapy waste, including syringes and items used in the preparation of chemotherapy infusions. Trace Chemo waste must be incinerated.
7. Isolation waste from Biosafety Level 4 agents aka from patients with highly communicable diseases as defined by the CDC.

Beyond the seven main categories, RMW is also defined as other infectious waste or other materials that have come in contact with infectious waste. Some of the subcategories of “other” RMW are potentially infectious waste, clinical waste, and special waste from healthcare-related facilities.

RMW Sorting, Packaging, and Storage Regulations

In times of high flow, such as during a pandemic, governing bodies can put in place additional regulations regarding the segregation, packaging, labeling, and storage of RMW. No matter which regulations are currently in place, proper RMW handling aims to:

• Minimize the risk of infection
• Optimize handling and disposal of waste
• Educate RMW handlers and generators on compliance and other requirements
• Optimize storage

Dealing With the Complexity of RMW Disposal Head-on

With so many RMW regulations to comply with, it’s easy for RMW generators to make mistakes with the collection, transportation, treatment, and disposal processes. A professional medical waste management company like TriHaz can help make sure your facility is compliant and your employees are adequately trained. We offer compliance solutions such as free and convenient online training to protect your employees and facility against possible fines.

To learn more about how TriHaz can help take the complexity out of RMW handling and disposal for your facility, get in touch with us today.