An Overview of Regulated Waste Disposal

COVID-19 has amplified the need to understand regulated medical waste—and more importantly—regulated medical waste disposal.

Regulated medical waste (RMW) presents a number of compliance challenges because most rules governing it are defined at the state level. Adding to the complexity, rules for medical waste disposal often emanate from multiple state agencies.

By the EPA’s own account, “it is not always clear how overall rules will apply to a specific situation.” (Oh great.)

Nearly all states have enacted medical waste regulations, but standards vary widely. Some state medical waste disposal rules are fashioned after the Medical Waste Tracking Act, while others bear little resemblance.

Per the EPA:

“In most states, the environmental protection agency is primarily responsible for developing and enforcing regulations for medical waste management and disposal. Although in some states, the department of health may play an important role (e.g., MO, OK) or even serve as the primary regulatory agency (e.g., CO). Where both agencies are involved, typically the department of health is responsible for onsite management and the environmental agency is responsible for transportation and disposal (e.g., LA, MO).”

Interested agencies

At least four federal agencies have an interest in medical waste disposal rules:

• OSHA. RMW is more dangerous the nearer it is to its point of generation, and is, therefore, an occupational safety concern in addition to an environmental one. OSHA guidelines trump state & local ones if the latter are less strict.

• DOT. Regulated medical waste is considered a hazardous material, and its transportation is consequently subject to applicable DOT rules.

• CDC. Medical waste disposal methods must adhere to CDC guidelines for infection control.

• EPA. Companies claiming they can reduce RMW infectiousness with their chemical products must register them with an EPA bureaucracy called “The Office of Prevention, Pesticide, and Toxic Substances—Antimicrobial Division.”

What exactly qualifies as regulated medical waste?

This is fairly intuitive: If you have a waste stream that might be contaminated by blood, body fluids, or other potentially infectious materials, then you’re dealing with RMW, which is also called “biomedical” or “infectious medical” waste, depending on where you live and work.

Although there are “guidelines,” an explicit definition of medical waste in federal law is conspicuous by its absence. Instead, it’s left to individual state bureaucracies to determine which wastes are regulated or require special handling.

You can get some idea of what you’re up against here. But as we’re apt to advise: it’s important to get expert advice.

Categorization of regulated medical waste

Once you know that you’re dealing with RMW, you have to figure out what kind. There are six subcategories. Each has its own handling requirements, which are state-specific.

• Pathological waste. E.g. tissues, organs, body parts, and body fluids removed during surgery and autopsy
• Human blood and blood products. E.g. waste blood, serum, plasma, and blood products
• Microbiological wastes. Cultures and stocks of infectious agents such as laboratory specimens (E.g. culture dishes; transfer, inoculation, and/or mixing devices; discarded live and attenuated vaccines; etc.)
• Contaminated sharps. E.g. contaminated hypodermic needles, syringes, scalpel blades, pipettes, and broken glass
• Isolation waste. Wastes generated from patients who are isolated to protect others from a communicable disease
• Contaminated animal wastes. (I.e. carcasses, body parts, and bedding from animals intentionally exposed to pathogens in research, biologicals production, or drug tests

How to dispose of regulated medical waste

Most state laws require RMW to be rendered non-infectious before it can be disposed of as solid waste. This could be done simply by “burning the whole load into a crisp.” (The EPA’s own words—believe it or not.)

But alas, onsite incineration for regulated medical waste disposal spews mercury, dioxins, and other toxins into the atmosphere, which will earn you the close, critical, litigious, and expensive attention of the EPA—not to mention that of a gaggle of state & local agencies.

Thus, you’re going to have to transport any RMW offsite to a hazardous waste management facility; and thereby need access to both a transporter and a treatment company, each licensed or “permitted” to handle RMW.

You can learn about your local resources here.

Treatment technologies for regulated medical waste disposal

There are basically two treatment technologies for regulated medical waste disposal: heat and chemicals.

• Heat. The RMW is placed into a steam autoclave—a pressure chamber—and exposed to high-temperature steam. The same effect might be achieved with dry-heat systems; specialized microwave ovens; or plasma-arc technology: think welding heat.
• Chemicals. For small batches, chlorine compounds, ozone, alkalis, or other disinfectants such as peracetic acid or glutaraldehyde can be used to render RMW non-infectious.

The upshot

Regulatory hurdles for medical waste disposal are arguably more complicated than for any other kind of hazardous waste management, emanating as they do from multiple state agencies, as well as the EPA, DOT, CDC, and OSHA.

It’s crucial to get expert help. And thanks for reading our blog!