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Infectious Waste

Background Information
Managing Infectious Waste
Application for Special Waste Authorization (SWA)
Special Waste Authorization (SWA) Restrictions
OSHA Regulations
Statutes, Regulations and Guidelines
More Information


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 Iowa, infectious waste can potentially be  considered a “special waste,” and is managed by the state’s solid waste department. Special waste is any industrial process waste, pollution control waste, or toxic waste which presents a threat to human health or the environment or a waste with inherent properties which make the disposal of the waste in a sanitary landfill difficult to manage. Infectious waste is waste that is infectious, including but not limited to the following:

  • Contaminated sharps are all discarded sharp items derived from patient care in medical, research, or industrial facilities including glass vials containing materials defined as infectious, suture needles, hypodermic needles, scalpel blades, and Pasteur pipettes.
  • Cultures and stocks of infectious agents are specimen cultures collected from medical and pathological laboratories, cultures and stocks of infectious agents from research and industrial laboratories, wastes from the production of biological agents, discarded live and attenuated vaccines, and culture dishes and devices used to transfer, inoculate or mix cultures.
  • Blood and blood products.
  • Pathological wastes are human tissues and body parts that are removed during surgery or autopsy.

Contaminated animal carcasses are wastes including carcasses, body parts and bedding of animals that were exposed to infectious agents during research, production of biologicals, or testing of pharmaceuticals.

Managing Infectious Waste

Medical waste management is regulated under the state’s solid waste program, if it is treated properly. Infectious solid waste which is generated and treated at a medical clinic, doctor’s office, nursing care facility, health care facility, dentist’s office or other similar facility may be placed with municipal solid waste and not handled in a special way if it is rendered nonpathological, does not contain free liquids, and sharps are shredded, blunted, granulated, incinerated or mechanically destroyed.

Application for Special Waste Authorization (SWA)

Generators of special waste shall make application for an SWA by submitting the form Request for Special Waste Authorization, accompanied by required supporting data. Three copies shall be submitted to the landfill, and the landfill will forward two of the copies to the department  for review.. The application shall include the following information when applicable:

  • Appropriate chemical analysis of the waste;
  • Physical form of the waste;
  • Weight or volume of the waste;
  • Material safety data sheet (MSDS) for the waste or for the materials from which the waste is generated, if applicable;
  • Toxicity characteristic leaching procedure (TCLP) test results when appropriate, which show that none of the federal limits in 40 CFR Part 261 are exceeded, and
  • Any other information requested by the department.

In addition:

  • The waste shall not contain free liquids as defined in 567- 100.2(455B, 455D). The point of compliance shall be the working face.
  • The waste shall not be a listed hazardous waste or meet the criteria for characteristic hazardous waste pursuant to the federal RCRA regulations.
  • Wastes with PCB concentrations equal to or greater than 50 ppm shall not be authorized for disposal at a landfill.
  • Polynuclear aromatic hydrocarbon (PAH) (SW 846 Method 8270) contaminated soil shall not be authorized for disposal at a landfill if the total PAH level exceeds 1600 ppm for listed compounds, pursuant to chapter 109.
  • Special waste authorizations may be issued for a period not to exceed three years.

Special Waste Authorization (SWA) Restrictions

  • The department may revoke an SWA for cause at any time. Such cause may include, but is not limited to, evidence that indicates that the characteristics of the authorized quality of the waste vary from the authorized values, evidence that the continued disposal of the waste as authorized may pose a threat to the public health or the environment, or failure to comply with any condition in the SWA or the landfill’s SWAC.
  • The holder of an SWA must apply for a renewal at least 30 days prior to the expiration of the SWA.
  • The issuance of an SWA does not obligate any waste disposal facility to accept the waste nor does it preclude the facility from imposing conditions or restrictions other than those listed in the SWA.
  • The issuance of an SWA does not exempt the party disposing of the waste from any local, state, or federal laws or regulations.

IAC 6/11/03Generator Responsibilities for Special WasteSpecial waste responsibilities for generators shall include, but are not limited to, the following:

  • Prior to submission of an SWA application, the generator shall adhere to the solid waste management hierarchy. Alternatives include volume reduction at the source; recycling and reuse, including composting and land application; and other approved techniques of solid waste management including, but not limited to, combustion with energy recovery and combustion for waste disposal.
  • The generator shall include, as part of the SWA application, a description of the review of the alternatives to landfilling for each waste for which an SWA is requested. The description should detail to what extent the waste could be recycled, reduced or reused so that landfilling is not necessary.
  • The generator shall follow the guidelines for submission of an SWA application as given in the regulations.
  • The generator shall ensure that special waste coming into the landfill shall arrive as a separate load and not be commingled with any other waste.
  • The generator shall submit analytical results supporting an SWA at a frequency to be determined by the landfill.
  • After receiving an SWA, the generator must contact the designated landfill for instructions on delivering the waste and instructions for adhering to the landfill’s Special Waste Acceptance Criterial or SWAC.
  • The generator shall notify the department and landfill, prior to disposal, of any change in the characteristics of the special wastes being disposed.
  • Generators shall notify the landfill in writing when a one-time disposal under an SWA has been completed. This requirement is for one-time disposals only.

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. Iowa is one of 21 states operating an approved occupational safety and health program. This program is operated by the Labor Services Division. The Labor Services Division is responsible for about a dozen programs designed to protect the safety, health and economic security of all Iowans. Their programs protect people who ride on elevators, escalators and amusement rides. They protect anyone who enters a building with an asbestos abatement project or a public building with a boiler. They protect employees from dangers in the workplace and protect employees' rights to be paid wages. They protect Iowa's children from dangers in workplaces and enhance their educational experiences. The Division enforces safety in the workplace, provides consultation to employers on occupational safety health compliance and maintains statistical information of workers' illness and injuries.

Statutes, Regulations and Guidelines

Iowa Infectious Waste Definition (IAC 567, Chapter 100)

Iowa Special Waste Authorizations - Infectious Waste Management (IAC, Chapter 109, 567-109.9-455B, 455D)


Iowa DNR Solid Waste Section

Iowa DNR, Air Quality Bureau

More Information

Iowa - Request for Special Waste Authorization Form