Last updated on January 24, 2019
In honor of National Spay/Neuter Awareness Month and World Spay Day (February 27), we’re highlighting a specific segment of medical waste generators – veterinary hospitals and clinics. Many veterinary practices are small businesses that play large roles in their communities by keeping pets healthy, supporting animal rescue organizations, and helping stop the spread of rabies and other diseases.
Because pet owners most often visit veterinary offices for preventative care – vaccinations, spay/neuter surgeries, etc. – it’s easy to forget that they are often small hospitals that can generate many of the same types of medical waste as human hospitals and medical offices. Indeed, for most companion animals, a veterinary hospital offers primary care, surgical care, emergency care, dental care, and end-of-life care. So, it’s no surprise that veterinarians must understand how to safely package and dispose of many types of regulated medical waste.
AVMA Offers Biohazardous Waste Disposal Guidelines/Education for Veterinary Practices
The American Veterinary Medical Association (AVMA) has a number of policies regarding waste disposal. In addition to these general statements of policy, the AVMA also maintains a members-only area of the organization’s website, which includes tips on medical waste handling. However, the AVMA warns against using the information as a comprehensive guide and recommends going directly to federal and state regulatory agencies, which are often the best sources for compliance.
That’s excellent advice. If a clinic or hospital is unsure of the regulations, it’s important to ask for guidance from regulators and experienced medical waste disposal companies. Confusion can lead to mistakes, which are not only costly but also present a risk to hospital employees, the community, and the hospital’s reputation.
Veterinary Clinics that Violate Medical Waste Disposal Regulations Can Face Fines & Regulatory Action
Some veterinarians may have been slow to realize that disposal regulations applied to their clinics and hospitals, not just the ones for humans. Several high-profile events, however, quickly raised awareness.
In 2009, Arizona Department of Environmental Quality (ADEQ) cited a veterinary hospital for improper disposal of used needles and syringes. The initially levied $96,000 fine was “the equivalent of what ADEQ estimated the biohazardous waste collection would have cost him over the last decade.” In 2011, the parties negotiated a $65,000 settlement that combined a cash fine with donated services to the local Humane Society. The practice owner also contracted with a medical waste disposal company for regular pickups.
Also in 2009, a veterinary practice in Rhode Island faced a possible $25,000 fine to cover the cost of repackaging “a 30-yard waste load that was rejected at the landfill because it contained used needles, pipettes filled with blood and a few blood samples in vials.” As with the Arizona case, the problem was lack of awareness about disposal regulations and regulated medical waste classification:
“They thought it was unreasonable to consider it medical waste because it didn’t contain any pathogens,” says Mark Dennen, principal environmental scientist as the Rhode Island Department of Environmental Management (RIDEM), of the unnamed veterinary clinic at fault. “But there’s no way of knowing, looking at a needle to tell if it’s contaminated with a zoonotic disease or, for humans, HIV. We treat all sharps as contaminated because there’s no way you can get to the level of knowing anything is totally safe.”
At the time of these incidents, there was often a lack of educational resources for veterinarians. The Rhode Island clinic escaped any fines and penalties because of that, state officials noted:
“Most of them are very small businesses. We hate to see that happen. In this case, it seemed it was just them not realizing what was regulated,” Dennen says. “We’d really rather see them be compliant than hit them with such a severe cost.”
Pet Hospitals Also May Be Improperly Disposing of Inventory Medications that Expire or Go Unused
Proper disposal of medications used in veterinary practices can also be very confusing. Drugs used for infusing chemotherapeutics, for example and expired inventory medications can fall under several different types of drug classifications with regard to disposal. They may be considered hazardous waste pharmaceuticals (HWP), controlled substances, or drugs that are neither. Reaching out to a full-service medical waste disposal provider can help find the best and most compliant solutions for these waste streams.
Veterinary Clinics & Hospitals Must Juggle a Patchwork of Regulations & Enforcement Agencies
No veterinary medical clinic would ever intentionally put staff, patients, or the community at risk by improperly handling or disposing of regulated waste. Compliance, however, isn’t always easy. Multiple federal agencies, state regulators, and local governments offer regulations and guidance on regulated medical waste disposal.
Most state medical waste regulations cover all generators doing business in that state. However, there are states in which counties and even cities take on that enforcement responsibility. California is the most populous state in the country and has the largest number of employed veterinarians – over 6,000. California law allows county and municipal governments (Local Enforcement Agencies – LEAs) to enforce the California Medical Waste Management Act. At present, 32 counties and two cities have oversight authority, while the remaining 25 counties and one city rely on the California Department of Public Health. This map shows the patchwork of enforcement entities in the state.
Veterinary clinics and hospitals with locations in multiple California counties, must deal with individual LEAs when registering as a generator and complying with regulations and inspections. An even further challenge falls on organizations with hospitals across the country that must comply with specific regulations unique to each state. A qualified medical waste disposal company can help any size veterinary organization comply with medical waste storage, disposal, tracking, and other regulations. At Sharps Compliance, our medical waste management experts can develop compliance programs for a single clinic or chains with hospitals across the country.
When it comes to documentation of proper disposal, SharpsTracer prevents scrambling to find lost manifests during an inspection or audit. SharpsTracer allows customers to track and verify the receipt and treatment of returned materials as required by state and federal regulations, while eliminating the need for paper-based manifest tracking.
Contact us to learn more about how our medical waste management systems can help protect not only veterinary practices but also pets, pet owners, and our communities.