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Infectious Medical Waste

Background Information
Definition of Infectious Medical Waste
Managing Infectious Medical Wastes
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 Medical Waste

An infectious waste is defined by statute as a “solid waste that contains or may reasonably be expected to contain pathogens of sufficient virulence and quantity that exposure to the waste by a susceptible host could result in an infectious disease.”  This waste includes such materials as used sharps, body fluids or materials mixed with body fluids, bandages, or other materials that have come in contact with body fluids.

The state of Utah uses the term “Infectious Waste” which is waste that is capable of producing an infectious disease.  This definition requires a consideration of the factors necessary for introduction of disease, which includes doses, host susceptibility, presence of a pathogen, virulence of a pathogen, and the most commonly absent factor, a portal of entry.  Therefore, for waste to be infectious, it must contain pathogens with sufficient virulence and quantity so that exposure to the waste by a susceptible host could result in an infectious disease.  Because there are no tests that allow infectious waste to be objectively identified, the waste is considered to be infectious when it is suspected to contain or has the potential to contain pathogens in sufficient numbers to cause disease.

Managing Infectious Waste

The Division of Solid and Hazardous Waste uses the Infectious Waste Management Guidance to interpret Rule R315-316 in the management of infectious medical waste.  To protect human health and the environment, the Infectious Waste Requirements (Rule R3150316 of the Utah Solid Waste Permitting and Management Rules) became effective on July 15, 1993.  These requirements are applicable to infectious waste after it has been removed from the health care facility to be stored, transported or disposed.  The OSHA Bloodborne Pathogen Standard regulates the handling of infectious waste inside health facilities.  The OSHA standard requires that all infectious waste be isolated in conspicuously colored or labeled containers and for sharps, the containers must be puncher-proof.  The Utah rule sets minimum standards for the storage, transportation, and disposal of infectious waste from health facilities that generate more than 200 pounds of infectious waste per month.  If infectious waste has been rendered noninfectious, the waste material may be managed as other noninfectious waste provided it is not an otherwise regulated hazardous or radioactive waste.

Large Health Facilities

The Utah Infectious Waste Requirements apply to larger health facilities such as hospitals and clinics that generate more than 200 pounds of infectious waste per month.   Several local health departments have rules that are different in some ways from the state requirements.  The local health department should be contacted for specific requirements for the management of infectious waste.  A general summary of the state requirements for the management of infectious waste by a large health facility follows:

  • Prepare, maintain on file, and follow an infectious waste management plan and otherwise meet the requirements of the OSHA Bloodborne Pathogen Standard.
  • Except for sharps, isolate infectious waste in secured plastic bags or rigid containers.  The containers must be red or orange or clearly identified with the international biohazard sign and labeled “INFECTIOUS WASTE,” OR “BIOHAZARD”.
  • If storage is necessary, protect infectious waste from the elements in a storage area which is ventilated to the outside and accessible only to authorized persons.  The storage area must be marked with prominent warning signs.  If infectious waste is to be stored longer than seven days, it must be stored at or below 40 Fahrenheit (5 Celsius).

Infectious Waste Transportation

Transporters of infectious waste are regulated when they have more than 200 pounds in the vehicle at one time.  Transporters must:

  • Transport infectious waste separate from other waste unless the waste is contained in a separate, fully enclosed leak-proof container with in the vehicle compartment or unless all of the waste in the vehicle is to be treated as infectious waste.  Vehicles transporting infectious waste must meet all requirements of the Department of Transportation.
  • Transport infectious waste using equipment that will contain all waste so that there are no releases of infectious waste to the environment.
  • Provide training for drivers in waste handling and spill cleanup methods.
  • Label vehicles by DOT standards.
  • Have spill kit available.
  • Clean all surfaces of transport vehicles when spills have occurred.
  • Store waste no longer than 7 days without refrigeration and no longer than 30 day total.

Infectious Waste Treatment and Disposal

Infectious waste must be treated or disposed at a facility with a permit or other form of approval.  After being rendered noninfectious, the waste may be managed as a noninfectious solid waste.  Approved treatment or disposal methods include:

· Infectious waste may be incinerated in an incinerator that has a permit or other approval from both the Division of Solid and Hazardous Waste and the Division of Air Quality.

· Infectious waste may be sterilized by heating in a steam sterilizer to render the waste noninfectious.  After sterilization, the waste may be managed as a noninfectious solid waste.

· Other methods may be used to render infectious waste noninfectious.  Prior to its use, any other method must be approved, on a site-specific basis, by the Executive Secretary of the Utah Solid and Hazardous Waste Control Board. 

· Liquid or semisolid infectious waste may be discharged to a sewage treatment system that provides secondary treatment of waste if approved by the operator of the sewage treatment system.

· Infectious waste may be disposed in a permitted Class I, II, or V Landfill.  Upon entering the landfill, the vehicle operator must declare that the load contains infectious waste and must follow any procedures required by the landfill operator.

Small Health Facilities and Small Quantity Transporters

Small health facilities that generate 200 pounds or less, of infectious waste per month and transporters that transport less than 200 pounds per load are not regulated by the Utah Infectious Waste Requirements.  Several local health departments have requirements that apply to health facilities that generate lower amounts of infectious waste and transporters that transport small amounts of infectious waste.  One should contact their local health department for requirements that may be different from the state rule.

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.  Utah is one of 24 states operating an approved occupational safety and health program.  This program is operated by the Utah Occupational Safety and Health.  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.  These requirements can be found in the HERC section entitled OSHA Standards for Regulated Waste.

Home Health Care

Infectious waste generated by home health care activities is not regulated by state rules.  Local health departments may have rules that differ from the state rules. Contact them for specific rules.  The following procedures should be followed to minimize the potential risk from exposure to infectious waste.

  • Except for sharps, materials must be isolated that have come in contact with body fluids, in a plastic bag or a leak resistant rigid container.  The containers of infectious waste may be placed in the regular household waste container for curbside collection.
  • Isolate sharps in leak-proof, rigid, puncture-resistant containers such as a plastic soft drink bottle, a plastic milk bottle, or a sharps container commercially available at many pharmacies.  When the container is full of sharps, the lid should be tightly secured and taped on.  The sharps container may then be placed in the regular household waste container for curbside collection.
  • Liquid and semisolid infectious waste may be washed down the sewer using plenty of water.