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Michigan

Medical Waste

Background Information
Medical Waste Definition
OSHA Regulations
Contact


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.
  • Pathological waste must be disposed of by one or more of the following methods:
    • Incineration or cremation.
    • Grinding and flushing into a sanitary sewer.
    • Burial in a cemetery, if transported in leak proof containers of sufficient integrity to prevent rupture.
    • Grinding until rendered unrecognizable, stored in closed, puncture-resistant, properly labeled containers, and, if not in liquid form, disposed of in a sanitary landfill.
    • A process approved by the Department.
  • Sharps must be disposed of by one of the following methods:
    • 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.
    • Incineration or decontamination and grinding that renders the objects unrecognizable. Ground sharps must be placed in a sealed, rupture-resistant container and transported to a sanitary landfill.
    • A process approved by the department.
  • Animal waste contaminated with organisms infectious to humans must be disposed of by incineration or by burial in a sanitary landfill in properly labeled, double containers that are leak proof and puncture-resistant and are tightly sealed to prevent escape of fluids or material. Contaminated animal organs disposed of separately must be rendered unrecognizable.

Training

Healthcare facilities that generate medical waste must provide instruction in the proper handling of medical waste according to the facility's medical waste management plan to its employees who generate and/or dispose of medical waste.  A facility must assure that an employee who handles medical waste is trained before the employee assumes duties that involve the handling of medical waste to enable the employee to handle and dispose of medical waste in a safe and proper manner.  All employees must receive refresher training when a change in the producing facility's medical waste management plan occurs that directly affects the employee's duties.

Healthcare facilities that generate medical waste must create and retain a record of the training of employees who handle medical waste. The record must include: employee's name; job classification; and dates of training.

A facility that produces medical waste must retain its training records for a minimum period of 3 years.

OSHA Regulations

In addition to the state medical waste environmental regulations there are some Occupational Safety and Health Administration (OSHA) rules that apply to medical/infectious waste.  Michigan is one of 24 states operating an approved occupational safety and health program.  This program is operated by the Michigan Occupational Safety and Health.  OSHA rules (Occupational Exposure to Bloodborne Pathogens Standards) impact various aspects of medical/infectious waste, including management of sharps, requirements for containers that hold or store medical/infectious waste, labeling of medical/infectious waste bags/containers, and employee training.  These requirements can be found in the HERC section entitled OSHA Standards for Regulated Waste.

Regulations

Part 138, Medical Waste Regulatory Act, of the Michigan Public Health Code, 1978 Pa 368, as Amended

Contacts

To obtain an application or if there are any questions, please contact John Gohlke at 517-241-1320 or gohlkej@michigan.gov

More Information

Michigan DEQ Medical Waste Program