Last updated on January 24, 2019
Every medical waste generator must have a solid understanding of the different types of regulated medical waste. Approximately 15% of the waste generated in healthcare is deemed regulated medical waste, and proper handling is critical. Improper disposal can spread disease and leave your facility open to fines and lawsuits. Make sure your staff understands what constitutes regulated medical waste and is appropriately trained on its handling, containment, packaging, labeling, storage, transport, and disposal.
Definition of Regulated Medical Waste
Individual states define regulated medical waste (RMW). The Department of Transportation (DOT), Environmental Protection Agency (EPA), United States Postal Service (USPS), and Occupational Safety and Health Administration (OSHA) all have definitions of regulated medical waste management based on the specific agency’s jurisdiction. In other words, OSHA is concerned about employee handling, DOT and USPS are concerned about the waste while in transport, EPA is concerned about the treatment and disposal of such waste, and individual states can cover all the above regarding their own state.
While the term “medical waste” refers to any waste resulting from medical diagnosis, treatment, or research, very little of that waste is regulated. OSHA and other regulatory agencies use the term “regulated medical waste” to describe medical waste that “contains enough blood or other potentially infectious materials (OPIM) to potentially spread bloodborne pathogens.” OPIM is defined as certain body fluids, other than blood, that could contain enough of a bloodborne pathogen to cause infection if transmitted through non-intact skin, mucous membranes, or punctures. These body fluids (OPIM) include semen, vaginal secretions, cerebrospinal fluid, synovial fluid, pleural fluid, pericardial fluid, peritoneal fluid, amniotic fluid, saliva in dental procedures, ANY body fluids that are visibly contaminated with blood, ALL body fluids in situations where it is difficult or impossible to differentiate between body fluids, and any unfixed human tissue or organ from a human.
There are several terms for RMW that are often used interchangeably. Preferred terms can vary by state as well:
- Regulated Medical Waste (e.g., NY, RI)
- Infectious Waste (e.g., CO, NE, NV)
- Biomedical Waste (e.g., CT, FL, GA, ME, WA)
In addition to those designations, these terms also refer to regulated medical waste or subcategories of medical waste:
- Biohazardous waste
- Infectious medical waste
- Potentially infectious waste
- Hospital waste
- Healthcare waste
- Healthcare-related waste
- Biological waste
- Clinical waste
- Special waste from a healthcare-related facility
Types of Regulated Medical Waste
These seven types of regulated medical waste are most commonly subjected to state regulation.
- Contaminated sharps waste (e.g., needles, syringes with needles attached, scalpels, blood-contaminated broken glass, dental carpules with blood in them): “Sharps” are any objects that can puncture the skin. Sharps waste can be particularly dangerous because these instruments were designed to cut and puncture. Proper containment in FDA-approved sharps disposal containers followed by DOT or USPS-compliant secondary packaging for transport is essential for safe sharps disposal and transportation.
- Pathological and anatomical waste: These wastes are comprised of tissues, body parts, and organs removed during surgery or small amounts of tissue removed for study. Anatomical waste specifically refers to recognizable human organs and body parts. Many states have special handling and disposal regulations. This waste type should be packaged and labeled for incineration. Your medical waste transporter can assist with proper “PATH” labels to assure your waste is properly segregated and transported for state-compliant treatment and disposal.
- Microbiological waste: Most commonly generated in laboratories, this waste consists of cultures, stocks, microorganisms, and biologicals. Any cultures or other items contaminated by this waste are also considered microbiological waste. Based on the infectious agents, generators may be required to autoclave this waste prior to transporting it offsite for proper treatment and disposal. This waste, like pathological waste, may need additional labeling as required by the medical waste transporter.
- Blood, blood products, and OPIM (e.g., blood in blood tubes, blood or OPIM in suction canisters): Liquid blood and OPIM can typically be disposed of down the sanitary sewer. However, it is always best to check with your local POTW if large volumes are to be sewered.
- Contaminated items that would release blood or OPIM in a liquid or semi-liquid state if compressed (e.g., blood-soaked gauze) and items that are caked with dried blood or OPIM and can release these materials during handling (e.g., blood-soaked gauze that has dried and the blood could flake off and bloody gloves or other items that have not absorbed the blood) are also regulated.
- Isolation waste: Isolation wastes are wastes from patients infected with highly communicable diseases such as Ebola, Marburg, and other diseases listed in CDC Table 27. According to the CDC, they include biological waste and discarded materials contaminated with blood, excretion, exudates, or secretion from humans or animals who are isolated to protect others from highly communicable diseases.
Unless patients are infected with one of these highly communicable diseases, their wastes are managed as other regulated medical waste. For example, if a patient is isolated for C. diff, MRSA, or VRE (not highly communicable infectious diseases according to CDC Table 27), all contact precautions are practiced according to CDC Isolation Precautions. However, the wastes are managed like any other medical waste.
- Animal waste: Body parts, carcasses, and bedding from animals infected with zoonotic diseases, or exposed to pathogens during research must be handled and disposed of as infectious waste. Most states require that sharps used in veterinary care be managed as sharps waste. Non-infectious animal carcasses or large body parts should be properly managed per state regulations as well.
Because state and local regulations vary, refer to our state regulatory compliance map to learn about specific regulations that pertain to states in which you have facilities.