An Overview of Regulated Medical Waste Treatment Methods

This blog entry provides comprehensive information about proper regulated medical waste disposal treatment for RMW waste, also known as “biomedical waste” and/or “infectious medical waste.” Q&As include:

1. What exactly qualifies as regulated medical waste?

2. What agency is primarily responsible for developing and enforcing regulations regarding medical waste management and disposal?

3. What federal agencies regulate medical waste disposal?

4. How is regulated medical waste categorized?

5. How do you dispose of regulated medical waste?

6. What treatment technologies are used for regulated medical waste disposal?

7. What are the legal liabilities regarding regulated medical waste disposal?

8. Where can you get comprehensive help & advice regarding regulated medical waste disposal?

1. 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 regulated medical waste (RMW). But to confuse things, it’s also called “biowaste” or “biomedical waste” or “infectious medical waste,” depending on where you live, work, and to whom you’re speaking.

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

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.

2. What agency is primarily responsible for developing and enforcing regulations regarding medical waste management and disposal?

In most states, the EPA is primarily responsible for developing and enforcing regulations for medical waste management and disposal. Although in some states, the Department of Health might 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 EPA is responsible for transportation and disposal (e.g., LA, MO). (See Q.3) Sound confusing? Get expert advice.

3. What federal agencies regulate medical waste disposal?

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 Antimicrobial Program under the Office of Chemical Safety and Pollution Prevention (OCSPP).

4. How is regulated medical waste categorized?

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

5. How do you 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.

But alas, onsite incineration 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. (See Q.8)

6. What treatment technologies are used for regulated medical waste disposal?

There are basically three treatment strategies for RMW disposal: heat (see Qs 6.1, 6.2, and 6.3), chemicals (see Qs 6.4 and 6.5) and irradiation (see Q.6.6). More specifically:

6.1 Incineration. Onsite incineration is a relatively quick & easy disposal method for ridding the premises of RMW. In this process, RMW is subjected to a Dantesque inferno. We’re talkin’ temperatures ranging from 1,800°F to 2,000°F. But there are concerns about emissions. Thus, while some states and localities actively encourage incineration, others have enacted moratoriums on incinerators—or suspended permit applications for them—until the science catches up with the practice. (Incinerator curious? You can see which states allow them here.)

6.2 Autoclaving. Known simply as steam sterilization to the non-cognoscenti, this is the most common alternative to RMW incineration, as it’s both cheaper and cleaner. In this method, bags of waste are placed in a chamber and steamed at x-pressure and y-temperature for z-time until all the inhabiting microorganisms have been sent to their eternal reward. Thus sterilized, the bags of waste can be landfilled with the more-quotidian garbage at the city dump. (Autoclaving is generally contraindicated for pathological waste. The process might not completely sterilize it due to the waste’s ubiquity and composition.)

Fascinating factoid: Approximately 90 percent of regulated medical wastes, including the microbiological variety, are suitable for autoclaving or microwaving1. But they aren’t suitable for pathological, cytotoxic, or other toxic chemical wastes.

See Q.6.3

6.3 Microwaving. This method can achieve the same effect as autoclaving (see Q.6.2), and with less energy and drama. To wit, the RMW is shredded and mixed with water. The electromagnetic waves generated by the oven are absorbed by the water molecules inside & surrounding the RMW. This causes said molecules to rapidly shimmy n’ shake n’ vibrate. The resultant heat spreads throughout the RMW, rendering it sterile. Although the process is the same, these microwave ovens are, of course, a lot bigger and meaner than the ones commonly commissioned to defrost bagels. And unlike their kitchen counter counterparts, computer controls are used to ensure maximum disinfection. (Microwaving is generally contraindicated for pathological waste, as it might not achieve the necessary level of sterilization.)

6.4 Gas sterilization. Herein, medical waste is fed into an evacuated airtight chamber into which badass agents like ethylene oxide or formaldehyde are introduced. The resulting gas kills harmful infectious agents. However, it’s important to remember that the EPA is generally down on badass agents—particularly ethylene oxide—for being toxic and really smelling bad.

6.5 Chemical disinfection. This process uses chemical agents like chlorine for disinfection and is most appropriate for liquid RMW. However, if your heart’s set on using chemical disinfection for non-liquid RMW, you need to grind it up to expose enough of its surface (to the chemicals) than would be possible in its original chunky state. (Chunky regulated medical waste? Let’s not go there.) Anyway, resultant liquids are municipally sewered, while solid residues are municipally landfilled.

6.6 Irradiation. This involves exposing RMW to ionizing radiation, typically using gamma rays, electron beams, or X-rays. Such neutralizes its pathogens or harmful components by microbial inactivation and/or chemical degradation, making it safer for disposal or further treatment. The RMW must be shredded or crushed and placed in specialized containers (or on a specialized conveyor system) for controlled irradiation. Don’t try this at home. The facility handling the irradiation of hazardous waste must follow strict safety protocols to protect workers and the environment from radiation exposure. This includes using shielded rooms, monitoring radiation levels, and maintaining proper containment systems. And BTW, this method is not typically recommended for treating pathological waste under most regulations. While irradiation can be useful in sterilizing certain materials (such as medical equipment or some types of pharmaceutical waste), it’s neither a standard nor a preferred method for pathological waste disposal due to its ubiquity and typical composition. Incineration (see Q.6.1) and autoclaving (see Q.6.2) are the methods of choice.

7. What are the legal liabilities regarding regulated medical waste disposal?

In many ways, RMWs, biowastes, biohazard wastes, or biomedical wastes—call them what you will—are arguably the epitome of hazardous waste. And the RCRA stipulates that any entity that generates a hazardous waste is legally responsible for it—from the metaphorical “cradle-to-grave.”

This includes not only its onsite hazardous waste management, but also its subsequent transportation to a properly “permitted” or licensed offsite storage, treatment, or disposal facility. In other words, once you’ve generated a hazardous waste, there’s no way to rid yourself of complete legal responsibility for it: there’s no passing the buck if something goes wrong.

Obviously, these circumstances make it imperative that you apply a comprehensive approach to your hazardous waste management relative to RMW. Such an approach is a complicated undertaking. You need a business partner with the experience & expertise to help you develop and maintain a comprehensive system for managing your RMW legally and safely.

8. Where can you get comprehensive help & advice regarding regulated medical waste disposal?

You can trust and depend upon Hazardous Waste Experts. We offer documentable success providing all-inclusive hazmat services to hospitals and clinics relative to RMW—and at the most competitive prices.

Email us today or call our new number at 425.414.3485 to learn more.

And thank you for reading our blog!