This is an update of the article originally published on June 1, 2016. Regulations change frequently. That’s why Sharps Compliance monitors updates and communicates any changes to its customers.
Just when you thought that your waste was packaged properly, you learn that your state has laws that differ from federal regulations. Did you know that states have the authority to add additional rules to many federal regulations? It’s important to follow local, state, and federal requirements when packaging and labeling your waste. Here are a few simple steps that you can follow to lessen the potential environmental, safety, and financial risks associated with improper packaging of your medical waste.
As a “generator,” the person producing the waste, you are accountable for the proper classification, segregation, packaging, and sealing for transportation of your waste and subject to fines and penalties for any defaults. So, what are the best options for learning proper packaging of medical waste in your state?
First, you must identify which wastes are classified as regulated medical waste. Each state has a specific definition, very similar to OSHA’s definition included in the Bloodborne Pathogens Standard. According to OSHA, regulated medical waste includes:
- Liquid or semi-liquid blood or other potentially infectious materials (OPIM1 )
- Contaminated items that would release blood or OPIM in a liquid or semi-liquid state if compressed
- Items that are caked with dried blood or OPIM and are capable of releasing these materials during handling
- Pathological and microbiological wastes containing blood or OPIM
Next, you must properly package your waste for transport, according to the Federal Department of Transportation (DOT), as well as any specific state or local regulations. For example, some states require identification on the box if waste must be incinerated. Others may require generator identification on red bags and sharps containers. Others have time limits for the storage of your waste. Feel free to discuss these requirements with your service provider or check your specific state requirements here. Sharps Compliance customers gain access to our Regulatory Hub, which goes into even more detail about state regulations.
After setting up your transport box, place the provided red-bag liner inside the transport box, which is now ready for you to contain your full, sealed sharps containers and individually tied red bags. Loose sharps and free liquids are never allowed in the transport box. If you have large volumes of liquid waste to dispose of, please contact Sharps Compliance Customer Service at 800.772.5657 for the best disposal options.
As a reminder, please note that the following items should not be placed in the medical waste transport box:
- Items contaminated with urine, feces, sputum, tears, sweat, nasal excretions – unless those items are affixed with protected health information
- Regular trash
All of these items can be placed into the regular trash. If you place them in a medical waste transport box, then you are paying up to 10 times the amount to dispose of this waste as you would if placed them into the regular trash where they belong.
The items below MUST NOT be placed into the medical waste transport box. Contact Sharps Compliance at 800.772.5657 for the proper disposal systems for these materials.
- Hazardous and chemical waste
- Loose sharps
- Compressed gas cylinders
- Radiographic and amalgam waste
- Free liquids
Once the transport box is full or otherwise ready to be sealed2 , the red-bag liner must be closed by gathering and twisting the neck into a single knot or by using a twist tie. Next, fold the box flaps closed (they must lay flat on top of the box), and tape closed, making sure that the red bag is not visible. Keep in mind that if the box is damaged or not packaged correctly, then the driver will not be able to pick up the box at that time, and you will have to schedule a new pickup once the box has been packaged and sealed properly.
Apply the supplied barcode label to the exterior of the box on the indicated location and have the appropriate person sign the tracking form. The person who signs the tracking form should be knowledgeable about what is contained in the box and that it has been properly packaged and sealed. Keep your copy for the state-required length of time. All Sharps Compliance customers can access their proof of destruction and run needed reports at https://www.sharpsinc.com/sharps-tracer.
Click here to download our Medical Waste Packaging poster.
 OPIM (Other Potentially Infectious Materials):
(a) The following human body fluids: semen, vaginal secretions, cerebrospinal fluid, synovial fluid, pleural fluid, pericardial fluid, peritoneal fluid, amniotic fluid, saliva in dental procedures, any body fluid that is visibly contaminated with blood, and all body fluids in situations where it is difficult or impossible to differentiate between body fluids;
(b) Any unfixed tissue or organ (other than intact skin) from a human (living or dead); and
(c) HIV-containing cell or tissue cultures, organ cultures, and HIV- or HBV-containing culture medium or other solutions; and blood, organs, or other tissues from experimental animals infected with HIV or HBV.
 States differ regarding storage times for different waste streams. For a list of each state’s storage time limitations, call 800.772.5657 or check with your state’s environmental department website.