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Medical Waste

Background Information
Definition of Infectious Medical Waste
Management of Infectious Medical Waste
OSHA Regulations
Statutes, Regulations and Guidelines


Background Information

Medical waste differs from hazardous waste. Hazardous waste is regulated by the US EPA (and related state rules) under the Resource Conservation and Recovery Act. Medical waste is not covered federal environmental laws or US EPA regulations (with the exception of a medical waste that also meets the definition of hazardous waste). Rather, medical waste is mostly controlled by state law and associated regulations. In addition to state environmental agency laws/rules, aspects of medical waste management are also controlled by the Occupational Safety & Health Administration (federal and/or state) and Department of Transportation (federal and state).

Each of our 50 states have developed rules and implemented regulations for medical waste. The state rules vary to some extent, including terminology. Depending on which state you live in, you may hear the terms regulated medical waste, biohazardous waste or infectious medical waste. In most cases, these terms all refer to the same thing: that portion of the medical waste stream that may be contaminated by blood, body fluids or other potentially infectious materials, thus posing a significant risk of transmitting infection.

Most states have regulations covering packaging, storage, and transportation of medical waste. Some states require health care facilities to register and/or obtain a permit. State rules may also cover the development of contingency plans, on-site treatment, training, waste tracking, recordkeeping, and reporting.

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 or even serve as the primary regulatory agency. Where both agencies are involved, typically the department of health is responsible for on-site management and the environmental agency is responsible for transportation and disposal.

OSHA, whether it is the U.S. Department of Labor Occupational Safety & Health Administration or an OSHA state program (24 states operate their own program), regulates several aspects of medical waste, including management of sharps, requirements for containers that hold or store medical waste, labeling of medical waste bags/containers, and employee training. These standards are designed to protect healthcare workers from the risk of exposure to bloodborne pathogens. However, they also help to systematically manage wastes, which benefit the public and environment.

Regulated medical waste is defined by the US Department of Transportation as a hazardous material. DOT rules mostly apply to transporters rather than healthcare facilities; although, knowledge of these rules is important because of the liability associated with shipping waste off-site.

Definition of Infectious Waste

In Colorado, infectious waste is defined as any waste capable of producing an infectious disease in a susceptible person. Generally recognized infectious wastes include, but are not limited to: isolation wastes from persons having a disease requiring Biosafety Level IV containment; cultures and stocks of infectious agents and biologicals; human blood, blood products and other body fluids; human pathological or anatomical waste consisting of tissues and body parts; contaminated sharps; and contaminated research animals and bedding.

Managing Regulated Medical Waste

Management Plan. Healthcare facilities that generate infectious waste must develop and implement an on-site infectious waste management plan appropriate for their particular facility. This plan must be available to the hauler of the waste, to the disposal facility, and to the licensing or regulatory agency. The plan must include the designation of infectious waste, provisions for the handling of that waste, staff training, contingency planning for spills or loss of containment, the designation of a person responsible for implementation of the plan, and provisions for appropriate on and off-site treatment or final disposal.

Packaging and Labeling. Receptacles containing infectious waste must be clearly labeled with the biohazard symbol or with the words “Infectious Waste” in letters at least one inch high. Untreated waste must be stored, packaged, contained, and transported in a manner that prevents the release of the waste material and in a manner to prevent nuisance conditions. Contaminated sharps (needles, syringes, lancets) must be placed in a puncture resistant container and be properly designated as untreated infectious waste or made noninfectious by an appropriate treatment method. Untreated containers of sharps cannot be compacted.

Storage. There are no storage time limits for generators of infectious waste.  The waste need only be stored in a manner to prevent release of the waste and to prevent nuisance conditions.  

Off-Site Disposal in a Landfill. Properly labeled and packaged infectious waste may be disposed of in a permitted solid waste disposal facility without treatment. Landfills must be approved by their local governing authority and the state health department to accept this type of waste.  If untreated infectious waste is disposed of in a solid waste disposal facility, these procedures must be documented in the generator’s waste handling plan and must be acceptable to the waste hauler and disposal site. Recognizable human anatomical remains cannot be disposed of at a solid waste landfill. These must be either incinerated or interred.

Other Treatment/Disposal Options. Healthcare facilities may treat their infectious waste themselves to render it noninfectious or contract with a medical waste disposal company.  Infectious waste that has been appropriately treated to render it non-infectious is no longer considered infectious for handling and disposal purposes.  Treated waste can be disposed of with other noninfectious and nonhazardous solid wastes after the generator either identifies it as appropriately treated waste or provides the hauler and disposal facility with a written statement that its general waste includes appropriately treated infectious waste.  Appropriate treatment is any method that renders the waste noninfectious, and must include the following: documentation that the method is effective; a written standard operating procedure for implementation of the method; and regular monitoring to test the effectiveness of the treatment.  Widely used treatment methods include incineration, autoclaving, decontamination, and sterilization.

The Colorado Department of Public Health and Environment does not approve or recommend specific treatment methods, but leaves it up to the generator to determine what is an appropriate and effective treatment method for their wastes.

OSHA Regulations

In addition to the state medical waste environmental regulations there are some Occupational Safety and Health Administration (OSHA) rules that apply to medical/infectious waste. Colorado is one of 26 states covered entirely by the federal OSHA program. This program is operated by the Occupational Safety and Health Administration. OSHA rules (Occupational Exposure to Bloodborne Pathogens Standards) impact various aspects of medical/infectious waste, including management of sharps, requirements for containers that hold or store medical/infectious waste, labeling of medical/infectious waste bags/containers, and employee training.

Statutes, Regulations and Guidelines

Statements of Basis and Purpose and Specific Statutory Authority for 6 CCR 1007-2 Solid Waste Regulations.


Colorado Department of Public Health and the Environment--Hazardous Material and Waste Management Division

More Information

Information for health care facilities concerning medical waste.