When a healthcare facility generates regulated medical waste (RMW) or hazardous waste (HW), it has cradle-to-grave responsibility for that waste. That includes the safe containment, packaging, transportation, and tracking of wastes that leave the facility for treatment. The federal Department of Transportation (DOT) issues regulations governing this process for waste transported over the road, across waterways, or in the air. Waste generators must ensure that employees are correctly trained to segregate wastes, package and label them properly, and follow documentation guidelines.
DOT Hazardous Materials Classifications
The DOT regulates the transportation of wastes it deems capable of posing an unreasonable risk to safety, health, and property when transported. Under DOT guidelines, there are nine classes of hazardous materials. Although the EPA doesn’t define RMW as hazardous waste, RMW does fall under the DOT’s definition of hazardous material.
If your facility utilizes a pickup service for your RMW, you must follow DOT regulations as well as all state-specific regulations for waste classification, packaging, and treatment.
DOT-Mandated Employee Training
All employees involved in packaging or signing shipping documents for transporting regulated wastes via highways, waterways, or air shipments must receive DOT-required training.
It’s the employer’s responsibility to ensure that all eligible employees receive training within 90 days of hire (or reassignment), pass the required certification test, and undergo retraining every three years. New employees are allowed to perform hazardous waste duties during the initial 90-day period as long as a trained hazmat employee supervises them.
Be sure to retain the DOT Training Sign-in Sheet and DOT Training Certificates as proof that the DOT Training has been completed. Training records must include information for at least the last three years and must be retained for the length of each trained employee’s employment plus 90 days.
Proper Waste Classification
RMW and pharmaceutical waste must be properly classified and segregated for transportation and treatment/disposal. DOT has two categories for regulated medical waste:
- Category A: Waste capable of causing life-threatening or fatal disease or permanent disability in otherwise healthy humans or animals. Only specialized RMW companies handle Category A waste.
- Category B: Waste that IS NOT capable of causing life-threatening or fatal disease or permanent disability in otherwise healthy humans or animals.
There are different types of pharmaceutical wastes. Their classification depends on the chemical composition of each medication.
- Hazardous waste pharmaceuticals must be transported and disposed of by a certified hazardous waste hauler and facility. These wastes are EPA RCRA-listed wastes that are either toxic, flammable, corrosive, explosive, or a P- or U-listed drug. An estimated 5-10% of pharmaceuticals are classified as hazardous wastes when discarded.
- Non-hazardous pharmaceuticals may be picked up by an RMW transporter. These wastes must be packaged separately and marked for incineration.
Although only specific employees require DOT Hazmat training, other employees should receive training to help them property segregate medical waste. This helps you comply with federal and state regulations and control disposal costs. Regulated waste disposal costs up to ten times more than regular trash.
Our three-part series “What’s Going Into That Red Bag?” discusses the importance of proper segregation and offers guidance on reducing your volume of RMW through employee awareness and training.
Packaging Waste for Transport
Once the waste is properly segregated, it’s ready to be packaged for transport according to DOT regulations. Some state and local governments have additional regulations. For example:
- Identification on the box if the waste must be incinerated.
- Time limits on waste storage.
- Generator identification on red bags.
Sharps Compliance customers have access to free DOT packaging training 24/7 via our Regulatory Hub.
General requirements for RMW packaging include:
- Triple containment – primary container, secondary container, and a rigid outer packaging
- UN number marked on the outside of the transport container
- Used exclusively for the transportation of RMW
- Chemo waste, untreated stock cultures of Category B infectious substances, unabsorbed liquids, and sharps must be packaged in rigid inner containers (liquids in container cannot exceed 5 gallons)
There are also specific requirements for both sharp and non-sharp RMW packaging, including volume and weight limitations and puncture resistance. All sharps containers that exceed 20-gallon capacity must pass performance testing at the Packing Group II level.
Marking and labeling of RMW is also an important requirement of RMW generators. All of our large capacity TakeAway Recovery Systems are DOT-compliant and marked as follows:
- Biohazard label
- Required text for UN labeling as follows:
- Regulated medical waste, n.o.s., UN3291
- Orientation arrows
Download our medical waste packaging poster and post in a soiled utility room or other appropriate space to help staff remain compliant with RMW packaging requirements.
RMW Shipment Paperwork Requirements
Shipping papers must be completed by a DOT-trained employee and maintained as follows:
- Must be legible and in English
- Unless specifically authorized, the required shipping description may not contain any code or abbreviation
- Additional information must be placed after the basic description
- Actual shipping paper or an electronic image of the shipping paper must be retained at the place of business and made available upon request
- Unless state regulations require a different retention period, hazardous waste shipping papers must be retained for three years, and hazardous materials (RMW) shipping papers shall be retained for two years from the date of acceptance
Sharps Compliance customers have access to Sharps Tracer, an interactive web-based tracking and analytical program that helps you comply with your cradle-to-grave responsibilities, including proof of treatment that reflects the method and date of treatment as well as providing weight metrics. Use it to track and verify the receipt and treatment of returned materials as required by certain state and federal regulations. Sharps Tracer eliminates the need for paper-based manifest tracking. You can maintain your documentation in your secure Sharps Tracer account and/or keep hard copies for reference.
Contact us to learn how we can help you manage the safe containment, packaging, transportation, and disposal of your RMW, trace chemo, and pharmaceutical wastes. Our Takeaway Recovery Systems offer convenient mailback options for small quantity waste generators as well as DOT-compliant options for large quantity generators.