Who is Maintaining Your Medical Waste?

Red Bag Medical Waste

I don’t have time to close up and label the medical waste box
– so the medical waste transport driver does it.

This is a statement often uttered by busy employees responsible for managing their facility’s medical waste. Whether using a pickup service or mailing medical waste, only properly trained persons at the generating facility should package, label, and sign the tracking form for the waste shipment. That does not include a pickup service driver or untrained facility employee.

The US Department of Transportation (DOT) and individual states regulate transport and labeling of waste managed by a pickup service. Since the facility that generates this waste is responsible for the proper packaging, the DOT requires that anyone who “prepares medical waste for transport” must be trained in the proper procedure. Training must be documented and repeated every two years. In addition, states can require training as well.

When mailing medical waste, which is allowed only when using a USPS-approved mailback company, instructions are included with each mailback system, which can be used for training on proper packaging. DOT does not regulate mailback packages and therefore, does not require the training mandated by DOT. However, since the person packaging the waste is still responsible for properly doing so, it is important to train the employee using the mailback instructions.

When signing the manifest tracking form that must follow the waste from “cradle to grave,” the person signing the form declares that the contents have been classified, packaged, marked, and labeled according to applicable government regulations. This is true for both pickup service and mailback. That person declares that the shipment does not include hazardous materials, such as mercury or hazardous drugs. For this reason, only trained and designated employees, not a receptionist or pickup driver, must close or package the transport or shipping box and sign the manifest tracking form.

If your organization is using a pickup service, follow the driver’s instructions, which typically include the following:

  • Build out the box, making sure the box bottom is taped well and all closure and/or locking mechanisms are engaged and taped closed.
  • Place liner in the box.
  • Close sharps containers and tie up red bags prior to placing into lined box or container.
  • Place absorbent (such as kitty litter) into lined box if there is a chance of any liquid from sharps containers or red bags.
  • Securely tie closed liner around containers/bags.
  • Close the box flaps and secure with packing tape or secure the lid and closures.
  • Place label(s) as required by state regulations, including the label provided by the medical waste company.
  • Sign manifest tracking form (keep generator copy).
  • Provide box/container to pickup driver.
  • Access proof of treatment.

If you are using a mailback system, written instructions are included with each system. Instructions include the following:

  • Retain plastic-lined mailback box to ship containers back for treatment.
  • Close sharps containers and tie up red bags prior to placing into lined box/container.
  • Absorbent is already included in liner and/or each sharps container.
  • Securely seal liner around filled container(s) using provided twist or zip tie.
  • Close the numbered box flaps and place provided tape over closure tab(s).
  • Write facility return address on the top of the box. No additional labeling is required.
  • Complete and sign manifest tracking form (keep generator copy).
  • Provide to mail carrier.
  • Access proof of treatment.

Don’t get caught out of compliance! Only trained employees at each facility are responsible for securing and labeling the pickup or shipping box, signing the manifest tracking form, and maintaining proof of shipment and treatment. Our ComplianceTrac tool helps offices build plans and policies to address these issues.

Jan Harris

Author: Jan Harris

Jan Harris holds a masters degree in Occupational Health and Safety Management and is an authorized OSHA outreach trainer. She has worked as a consultant focusing on OSHA and medical waste compliance since 1990, and for Sharps Compliance since 1999.