Last updated on October 30, 2019
Healthcare workers are often surprised to learn that 85% of the waste generated at their facility is classified as solid waste and can be disposed of as regular trash. The remaining 15% is classified as either biohazardous, hazardous, or other regulated waste and must be handled, contained, and disposed of per state and federal regulations.
It is also unknown to many generators how their waste is transported, or even treated and disposed of, once it leaves their facility. Generators can be held liable if their waste is not classified, packaged, and labeled correctly. Not all regulated waste is treated the same. Therefore, waste must be shipped or transported for proper treatment and disposal at a facility permitted for that specific waste type. This article will address what happens to your regulated medical waste (RMW) once it leaves your facility.
Segregating and Packaging for Safe Transport and Treatment
Once your waste is correctly segregated and properly packaged, the only way the transporter knows the type of waste the package contains is by how it’s labeled. If your waste is transported to the wrong treatment facility because you didn’t label it correctly, employees can be injured, and machinery can be damaged. Your medical waste management company can help you understand proper segregation, packaging, and labeling of your waste so it ends up being treated according to regulations.
Primary containers used for RMW containment include:
- Plastic bags (red or yellow as applicable) – used for containment of RMW, such as bloody dressings, gauze, pathology, trace chemo, and other items classified as RMW
- Sharps containers – used to contain items that can puncture your skin, such as syringes with needles attached, scalpel blades, and broken glass with blood on it
- Hazardous and pharmaceutical waste containers – containers intended for disposal of hazardous waste and other non-RMW regulated wastes. Even though we are not addressing the disposal of these wastes in this post, it’s important to note that they should be a part of almost every healthcare facility’s waste management program.
Secondary containers used to hold and transport primary RMW containers include:
- The Department of Transportation (DOT) uses compliant single-use boxes or reusable tubs to contain red bags and sharps containers prior to pickup by a medical waste disposal transporter.
- The United States Postal Service (USPS) uses compliant single-use mailback packaging to contain sharps containers and red bags that are handed to the mail carrier for transport.
- Special labeling may be required on boxes or tubs so that those waste streams can be taken to the right type of treatment facility. This may include PATHOLOGY waste, TRACE CHEMO waste, and non-hazardous and non-controlled PHARMACEUTICAL waste, which all should be incinerated.
- Hazardous waste packaging and labeling are required for hazardous waste and hazardous waste pharmaceuticals – these waste types are NOT RMW.
The two most common methods of transporting RMW to a treatment facility are the traditional pickup service and the mailback disposal system.
As previously mentioned, the generating facility is responsible for the proper classifying, segregating, packaging, and labeling of their RMW for transport. The Department of Transportation requires specific training for all employees who package RMW for transport and for those employees who prepare the required shipping papers (often called a manifest or tracking document). This training should include the specific functions required by your facility and the RMW transporter to properly classify, package, and label your waste.
Mailback Disposal Systems
Mailback disposal systems are often more economical for facilities that generate small quantities of RMW. Medical waste sent through the US Mail must be packaged and labeled according to USPS regulations. The Sharps Compliance Sharps Recovery Systems are safe, economical disposal solutions for individuals and small RMW generators. Unlike the DOT, the USPS doesn’t require formal training for generators. However, the USPS does require those generators to be knowledgeable and compliant with USPS regulations for mailing RMW and to follow the instructions for use that must be included with each mailback. In addition, generators may only use mailback systems that have been 3rd-party tested and are labeled with a USPS authorization number on the shipping box.
Medical Waste Treatment Methods
RMW must be offered to a facility properly permitted for treatment of RMW. The two primary methods of treating medical waste are steam sterilization (autoclave) and incineration. Sharps Compliance owns both types of facilities, providing customers with the best options for their waste streams.
- Autoclave treats the RMW with heat, steam, pressure, and time. Most healthcare professionals are familiar with this method, as it is used to sterilize reusable instruments. This option can be used for the majority of RMW. Waste that is autoclaved is either taken to a landfill as is or shredded first. Sharps Compliance not only shreds autoclaved waste, we then send it to a waste-to-energy facility where it is used as an alternative fuel source to generate energy instead of ending up in a landfill.
- Incineration is used to treat medical waste that can’t be autoclaved. Examples include pharmaceuticals, pathological waste, and trace chemo waste.
The EPA, as well as state environmental regulatory agencies, govern medical waste treatment, including autoclave and incineration technologies.
Consequences of Improper Disposal
The generator’s liability for proper disposal of their RMW doesn’t end when the driver or mail carrier picks up their waste. They must assure they are utilizing permitted and approved transporters and treatment facilities to reduce potential liability. The Resource Recovery and Conservation Act (RCRA), the primary law regulating hazardous waste, was the first regulations establishing the “cradle-to-grave” concept of generator liability. From generation through final disposal, each entity that handles the waste is responsible for documentation of the proper chain of custody utilizing shipping papers/manifest. Sharps’ online tracking and manifest maintenance program, SharpsTracer, provides our customers with this proper documentation.
Improper RMW disposal affects not only the environment but also anyone coming in contact with it. Discarded sharps, for example, represent a serious hazard to workers in solid waste disposal and recycling facilities. In addition to regulatory fines and penalties, waste generators can also face civil penalties for improper RMW management. Two San Diego County hospitals paid almost $400,000 in fines in 2011 for “…failing to separate medical waste properly; unlawful transportation of medical and hazardous waste…”
A professional medical waste disposal company that provides both mailback and pickup service, such as Sharps Compliance, does more than provide proper packaging materials, transportation, disposal, and documentation. Sharps also helps you stay in compliance with federal and state regulations, therefore, reducing your chance of fines and lawsuits.
Sharps’ training and OSHA compliance platform, ComplianceTrac, is a password-protected compliance training program. With ComplianceTrac, your staff has 24/7 online access to up-to-date OSHA training, SDS management, safety plans, as well as audit capabilities. Sharps also provides its customers with a Regulatory Hub. The Sharps Hub includes registration, storage, and other state-specific information on both RMW and pharmaceutical waste disposal.