Background Information
Medical waste differs from hazardous waste. Hazardous waste is regulated by the US EPA (and related state rules) under the Resource Conservation and Recovery Act. Medical waste is not covered federal environmental laws or US EPA regulations (with the exception of a medical waste that also meets the definition of hazardous waste). Rather, medical waste is mostly controlled by state law and associated regulations. In addition to state environmental agency laws/rules, aspects of medical waste management are also controlled by the Occupational Safety & Health Administration (federal and/or state) and Department of Transportation (federal and state).
Each of our 50 states have developed rules and implemented regulations for medical waste. The state rules vary to some extent, including terminology. Depending on which state you live in, you may hear the terms regulated medical waste, biohazardous waste or infectious medical waste. In most cases, these terms all refer to the same thing: that portion of the medical waste stream that may be contaminated by blood, body fluids or other potentially infectious materials, thus posing a significant risk of transmitting infection.
Most states have regulations covering packaging, storage, and transportation of medical waste. Some states require health care facilities to register and/or obtain a permit. State rules may also cover the development of contingency plans, on-site treatment, training, waste tracking, recordkeeping, and reporting.
In most states, the environmental protection agency is primarily responsible for developing and enforcing regulations for medical waste management and disposal. Although in some states, the department of health may play an important role or even serve as the primary regulatory agency. Where both agencies are involved, typically the department of health is responsible for on-site management and the environmental agency is responsible for transportation and disposal.
OSHA, whether it is the U.S. Department of Labor Occupational Safety & Health Administration or an OSHA state program (24 states operate their own program), regulates several aspects of medical waste, including management of sharps, requirements for containers that hold or store medical waste, labeling of medical waste bags/containers, and employee training. These standards are designed to protect healthcare workers from the risk of exposure to bloodborne pathogens. However, they also help to systematically manage wastes, which benefit the public and environment.
Regulated medical waste is defined by the US Department of Transportation as a hazardous material. DOT rules mostly apply to transporters rather than healthcare facilities; although, knowledge of these rules is important because of the liability associated with shipping waste off-site.
Medical Waste Definition
Definitions
"Medical waste” means
any of the following that are not generated from a household, a
farm operation or other agricultural business, a home for the aged,
or a home health care agency:
- Cultures and stocks of infectious agents
and associated biologicals, including laboratory waste, biological
production wastes, discarded live and attenuated vaccines, culture
dishes, and related devices.
- Liquid human and animal waste, including
blood and blood products and body fluids, but not including urine
or materials stained with blood or body fluids.
- Pathological waste.
- Sharps.
- Contaminated wastes from animals that
have been exposed to agents infectious to humans, these being
primarily research animals.
"Pathological waste” means
human organs, tissues, body parts other than teeth, products of
conception, and fluids removed by trauma or during surgery or autopsy
or other medical procedure, and not fixed in formaldehyde.
Regulatory Overview
The MWRP administers and enforces
Michigan’s Medical Waste Regulatory Act (MWRA), and the rules adopted
pursuant to the act. The MWRA provides regulations for the handling,
storage, treatment, and disposal of medical waste. Its objective
is to protect those persons who come into contact with medical
waste from exposure to the risk of injury, infection, or disease
that is created from improperly disposed medical waste. The MWRA
mandates how producing facilities of medical waste must manage
their medical waste from the point at which it is generated to
its ultimate disposal point. Generators of medical waste are required
to register as producing facilities of medical waste under the
MWRA.
Registration
Healthcare facilities that generate
medical waste must register with the Department. There is a registration
fee associated with the registration process. Upon receipt of
a complete registration form and registration fee the Department
will issue a certificate of registration (valid for 3 years) to
the healthcare facility.
Management Plan
A healthcare facility that generates
medical waste must have a written medical waste management plan
that contains specific information relating to the handling of
all medical waste generated, stored, decontaminated, or incinerated
at the facility or transported off-site for treatment/disposal.
Segregation/Containment
The following rules must be observed
when a facility is not incinerating their medical waste on-site:
- Package, contain, and locate
medical waste in a manner that protects and prevents the medical
waste from release.
- Separate the categories of medical waste
at the point of origin into appropriate containers that are labeled
with a biohazard symbol or the words “medical waste” or “pathological
waste” in letters not less than 1 inch high.
- Do not compact or mix medical waste
with other waste materials before decontamination, incineration,
and disposal.
- If decontaminated medical waste is mixed
with other solid waste, clearly label the container to indicate
that it contains decontaminated medical waste.
- Store medical waste in such a manner
that prevents putrefaction and also prevents infectious agents
from coming in contact with the air or with individuals.
- If medical waste is stored outside of
the producing facility, store the medical waste in a secured
area or locked in a container that weighs more than 500 pounds
and prevent access to the area of container by vermin or unauthorized
individuals.
- Do not store medical waste on the premises
of the producing facility for more than 90 days.
If the medical waste is going to
be incinerated on-site, follow these procedures:
- Package, contain, and locate medical
waste in a manner that protects and prevents the medical waste
from release.
- Label the containers with a biohazard
symbol or the words “medical waste” or “pathological waste” in
letters not less than 1 inch high.
- Separate and dispose of sharps in one
of the following manners: (i) Placement in rigid, puncture-resistant
containers that are appropriately labeled and transported to
a sanitary landfill in a manner that retains the integrity of
the container; (ii) Incineration or decontamination and grinding
that renders the objects unrecognizable. Ground sharps shall
be placed in a sealed, rupture-resistant container and transported
to a sanitary landfill; or (iii) A process approved by the department.
- Do not store medical waste on premises
of the producing facility for more than 90 days.
On-site Treatment/Disposal
A healthcare facility may treat/dispose
of medical waste using the following methods:
- Cultures and stocks of material contaminated
with an infectious agent must be stored in closed, puncture-resistant
containers, decontaminated by autoclaving or incineration,
and disposed of in a sanitary landfill.
- Blood and blood products and
body fluids must be disposed of by one or more of the following
methods:
- Flushing down a sanitary sewer.
- Decontaminating by autoclaving or incineration.
- Solidifying.
- If not in liquid form, transferring
to a sanitary landfill.
- A process approved by the department.
