Part Two: What’s Going into that Red Bag?

regulated medical waste

Reducing Your Medical Waste Through RightClassificationSM – A Three Part Series

In part one of this series, we discussed how OSHA defines regulated medical waste (RMW). In the second part of this series, we will address how to properly segregate, contain, and dispose of RMW.

Who regulates RMW disposal?

While OSHA defines RMW and regulates its containment and safe handling by employees, individual states, Department of Transportation (DOT), United States Postal Service (USPS), and the Environmental Protection Agency (EPA) regulate the transport and disposal.

Although state regulations have many similarities, there are variations. For example, most states define facilities as small quantity or large quantity generators. There are often different requirements based on the volume of RMW a facility generates1.

Other state regulatory differences include:

  • Registration and permitting
  • Medical waste management plan development
  • Limits as to how long sharps and red bag RMW can be stored in the facility
  • Training requirements
  • Tracking form retention

How should RMW be properly contained?

According to OSHA’s BBP Standard, contaminated sharps shall be discarded immediately or as soon as feasible in containers that are closable, puncture resistant, leak-proof on sides and bottom, and labeled with the orange-red biohazard label or color-coded red. Containers must be constructed to contain all contents and prevent leakage during handling, storage, transport, or shipping. During use, containers for contaminated sharps shall be easily accessible and located as close as is feasible to the immediate area where sharps are used. They must be maintained upright throughout use, replaced routinely, and must not be allowed to overfill1. In addition, some states include additional requirements such as specific labeling.2

How should RMW be properly disposed?

Individual states regulate the disposal of RMW, and therefore, disposal options may differ.

Options typically include:

  • Purchasing a mailback system
  • Contracting with a pick-up service
  • Treating on site

 

The company chosen to dispose of your RMW should provide a variety of services in addition to disposal. For example:

  • Your company should help with state regulatory compliance, such as storage requirements. For example, if you are located in a state that limits the time your waste can be stored, make sure you use a small enough transport container to allow it to be completely filled before it must be removed from your facility. If you are in a state with no restrictions, a larger container may be more cost effective.
  • Your medical waste company should help you with proper segregation (RightClassification.) This will not only save money by keeping trash out of the red biohazard bags, it will help make sure hazardous items are properly disposed of as well.
  • Always ask how your waste is treated. Typically, your waste may be autoclaved and sent to a landfill, autoclaved and repurposed to avoid landfill disposal, or incinerated.

If your state allows onsite treatment, be sure and check which if any methods are approved by your state and local ordinances.

Watch for Part 3 of this series where we will discuss solutions to help implement your RightClassification program.

1) OSHA Bloodborne Pathogens Standard
2) State Medical Waste Regulatory Map

For more information on Sharps Compliance’s medical waste solutions, click here

Jan Harris

Jan Harris

Director of Environmental, Health and Safety at Sharps Compliance
Jan Harris holds a masters degree in Occupational Health and Safety Management and is an authorized OSHA outreach trainer. She has worked as a consultant focusing on OSHA and medical waste compliance since 1990, and for Sharps Compliance since 1999.
Jan Harris

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Author: Jan Harris

Jan Harris holds a masters degree in Occupational Health and Safety Management and is an authorized OSHA outreach trainer. She has worked as a consultant focusing on OSHA and medical waste compliance since 1990, and for Sharps Compliance since 1999.