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

Proper Segregation

Reducing Your Medical Waste Through RightClassificationSM – Part Three

In the first 2 parts (part 1, part 2) of this series, we defined Regulated Medical Waste (RMW) and discussed how it was regulated, contained and disposed. In the final part of this series, we will discuss what a facility can specifically do to reduce its volume of RMW through proper segregation (RightClassificationSM) and therefore reduce spending.

1. Review your policy.
Your medical waste management plan can be included as a part of your Bloodborne Pathogens Exposure Control Plan or it can be maintained as a separate policy document. Regardless, make sure RMW is clearly defined and employees are able to access your policy for clear guidance. For example, if your policy defines RMW as “blood and other body fluids” instead of “blood and OPIM” (with the definition of OPIM included), employees and even trainers may become confused. In addition, you must follow what your policy states. So make sure your policy is not forcing you to “wrong classify” your waste and spend more money than necessary.

2. Meet with staff.
In Part 1 of this series, we listed some common obstacles to RightClassification. Active involvement of employers and employees alike is an integral part of the RightClassification process. In addition, staff involvement and input is crucial to any successful waste segregation program. The clinical staff must feel comfortable with the fact that the facility does not intend to dispose of any RMW into the regular waste stream. At the same time, the staff must understand that trash should not be disposed of as RMW. Again, you are not trying to RightClassify. That means placing the right waste in the right container, be it RMW, trash, recycling, or hazardous. Sometimes new employees did not properly segregate at previous workplaces. Or the clinical staff is not aware of the cost of regulated medical waste disposal. In addition, they may have been told by waste hauling companies that “it’s just better to put everything in the red bag, just to be safe.”

3. Perform a RightClassification audit.
Before the next time you send your RMW for disposal, perform an audit of your trash cans, red biohazard bags, and sharps disposal containers to see what is in them. Take pictures to use at your next training. Ask employees why those gloves are in the red bag, for example. The answer might be that the red bag is the closest and most convenient container. Until you know the “why” and the “who,” you can’t really address the “how.”

4. Make needed changes.
If changes addressed in training are not implemented immediately, training may be unsuccessful. Employees need to be set up to succeed. That is done by making those changes easy and convenient. Here are some suggestions:

  • Remove red bag containers in all clinical areas. Remember the definition of RMW? The average small quantity generator will typically have little red bag waste. Therefore, clinical areas usually do not need red bag-lined containers in them.
  • Place a supply of small red bags in a drawer or on a medication cart for the rare occasion when the need arises.
  • Place regular trash containers in convenient areas (both employees and patients will throw trash in the most convenient container with the largest opening).
  • Update policies and procedures in your Exposure Control Plan/Medical Waste Management Plan.
  • Perform periodic audits of red biohazard bags, sharps containers, storage areas, and manifest tracking forms.

5. Evaluate Your Program.
Monitor compliance, ask and answer questions, and re-educate staff on the reasons for proper waste segregation. Update when changes occur and at least annually, not only the facility’s Bloodborne Pathogens Exposure Control Plan but also the medical waste management plan.

Change is rarely easy. Most people resist change to current medical waste disposal practices based on:

  • Misunderstanding of the need for change
  • Deep-seated belief that the change is wrong or unnecessary and therefore, disregard procedures leading to change
  • Misunderstanding the change process
  • Passive resistance due to issues other than the change itself
  • Lack of proper training
  • Making changes hard or inconvenient

The disposal cost for RMW is as much as 2000% more than disposal of regular trash. The proper segregation of regulated medical waste can redirect dollars that can be used for better patient care, needed equipment, increased number of employees, or increase in employee compensation. It simply does not make sense to waste facility resources in this way. Make sure the entire staff understands the real reasons for RightClassification.

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.