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.
Definition of Infectious
Medical Waste
An infectious
waste is defined by statute as a “solid waste that contains or
may reasonably be expected to contain pathogens of sufficient
virulence and quantity that exposure to the waste by a susceptible
host could result in an infectious disease.” This waste includes
such materials as used sharps, body fluids or materials mixed
with body fluids, bandages, or other materials that have come
in contact with body fluids.
The state
of Utah uses the term “Infectious Waste” which is waste that
is capable of producing an infectious disease. This definition
requires a consideration of the factors necessary for introduction
of disease, which includes doses, host susceptibility, presence
of a pathogen, virulence of a pathogen, and the most commonly
absent factor, a portal of entry. Therefore, for waste to be
infectious, it must contain pathogens with sufficient virulence
and quantity so that exposure to the waste by a susceptible host
could result in an infectious disease. Because there are no
tests that allow infectious waste to be objectively identified,
the waste is considered to be infectious when it is suspected
to contain or has the potential to contain pathogens in sufficient
numbers to cause disease.
Managing
Infectious Waste
The Division
of Solid and Hazardous Waste uses the Infectious Waste Management
Guidance to interpret Rule R315-316 in the management of infectious
medical waste. To protect human health and the environment, the
Infectious Waste Requirements (Rule R3150316 of the Utah Solid
Waste Permitting and Management Rules) became effective on July
15, 1993. These requirements are applicable to infectious waste
after it has been removed from the health care facility to be stored,
transported or disposed. The OSHA Bloodborne Pathogen Standard
regulates the handling of infectious waste inside health facilities. The
OSHA standard requires that all infectious waste be isolated in
conspicuously colored or labeled containers and for sharps, the
containers must be puncher-proof. The Utah rule sets minimum standards
for the storage, transportation, and disposal of infectious waste
from health facilities that generate more than 200 pounds of infectious
waste per month. If infectious waste has been rendered noninfectious,
the waste material may be managed as other noninfectious waste
provided it is not an otherwise regulated hazardous or radioactive
waste.
Large Health
Facilities
The Utah Infectious
Waste Requirements apply to larger health facilities such as hospitals
and clinics that generate more than 200 pounds of infectious waste
per month. Several local health departments have rules that are
different in some ways from the state requirements. The local
health department should be contacted for specific requirements
for the management of infectious waste. A general summary of the
state requirements for the management of infectious waste by a
large health facility follows:
