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. Definition of Regulated Medical WasteRegulated medical waste is defined by the Oklahoma Department of Environmental Quality as a waste or reusable material that contains an “etiologic agent” and is generated in the diagnosis, treatment or immunization of human beings or animals; research pertaining to the diagnosis, treatment or immunization of human beings or disabling or fatal disease. The term “etiologic agent” is synonymous with the term “infectious substance”. Examples of RMW include:
Healthcare Facility RMW RegulationsMedical waste is regulated by several Oklahoma state agencies. The applicable regulations of each agency are summarized below. Links are provided to the full text regulations. The Oklahoma State Department of Health: Hospital StandardsThe Oklahoma State Department of Health hospital standards require that each hospital establish an infection control program to provide a sanitary environment and avoid sources and transmission of infections. The program must include written policies and procedures for identifying, reporting, evaluating and maintaining records of infections among patients and personnel, for ongoing review and evaluation of all aseptic, isolation and sanitation techniques employed in the hospital, and development and coordination of training programs in infection control for all hospital personnel. The standards also require that the infection control program include specific policies related to the handling and disposal of biomedical waste. However, no specific guidance is provided. For more information, see Subchapter 11: Infection Control in Hospital Standards (Title 310. Oklahoma State Department of Chapter 667). The same regulation also covers design and construction requirements for hospitals (see Subchapter 49: General Medical Surgical Hospital Construction Requirements). Incinerators are required for destruction of pathological waste, unless arrangements are made with a licensed service to pick up the waste for disposal. Incinerators may be shared by two or more nearby hospitals. Basic design standards for incinerators are contained in the regulation. Oklahoma Department of Environmental Quality (DEQ)DEQ Solid waste management regulations are contained in Title 252 Department of Environmental Quality Chapter 515: Management of Solid Waste. The following summarize the requirements for healthcare facilities with regard to regulated medical wastes. Permits. Healthcare facilities are not required to obtain a DEQ solid waste permit. However, regulated medical waste processing facilities are required to be permitted (see: Subpart 23 Regulated Medical Waste Management, 252:515-23-1). Storage of Regulated Medical Waste. Healthcare facilities are not subject to the storage requirements of Title 252 Chapter 515. However, OSHA storage requirements do apply to healthcare facilities (see OSHA regulations below). Regulated medical waste processing facilities must meet the following storage standards for RMW.
Disposal of Regulated Medical Waste. The disposal of the following RMW is prohibited in a municipal solid waste landfill, a municipal solid waste receptacle or a municipal solid waste transfer station:
Liquid regulated medical wastes (except chemical wastes, or antineoplastic or cytotoxic drugs) may be discharged into the collection system of a publicly owned treatment works (POTW) within the generating facility if written approval of the POTW has been obtained and the POTW provides secondary treatment. Treatment of Regulated Medical Waste. Regulated medical waste must not be compacted. It must be treated by one of the following methods:
Occupational Safety and Health (OSHA)Oklahoma is one of 26 states covered entirely by the federal OSHA program. OSHA rules impact several aspects of regulated medical waste, including management of sharps, requirements for containers that hold or store RMW, labeling of RMW bags/containers, and employee training. These requirements can be found in the HERC OSHA Standards for Regulated Waste section. ContactsOklahoma Department of Environmental Quality Additional ResourcesDEQ Regulations: Title 252, Chapter 515. Management of Solid Waste.
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