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Vermont

Regulated
Medical Waste

 

Background Information
Definition of Regulated Medical Waste
Managing Reglated Waste
Occupational Safety and Health (OSHA)
More Information
Contacts
Statutes, Regulations and Guidelines
Additional Resources

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 Regulated Medical Waste

A regulated medical waste (RMW) is that portion of waste generated in the medical industry which requires special handling and treatment prior to disposal.  The following types of solid waste are considered RMW:

  • Pathological Waste:  Human tissues, organs, and body parts that are removed during surgery, autopsy, obstetrical, or other medical or diagnostic procedures.
  • Human blood, blood products and other body fluids:  These are generated in patient care, testing and laboratory analysis or the development of pharmaceuticals.
  • Cultures and stocks of infectious agents:  These include cultures from medical and pathological laboratories, cultures and stocks of infectious agents from research, industrial and educational labs, discarded live and attenuated vaccines, and culture dishes and devices used to transfer, inoculate, and mix cultures
  • Sharps.
  • Animal Waste: Animal carcasses, bedding and body parts form animals that are known or suspected by either the Department of Health or the Department of Agriculture of being contaminated with organisms that can produce disease in humans and that disposal by ordinarily acceptable means would not sufficiently reduce the risk of transmission of a disease to humans or other animals.
  • Chemotherapy waste:  Any non-hazardous material containing cytotoxic/antineoplastic agents and/or antineoplastic agents during the preparation, handling and administration of such agents.
  • Infectious isolation waste:  Biological waste and discarded materials contaminated with blood, body fluids, excretion, exudates or secretions from humans who are isolated to protect others from dangerous communicable diseases.
  • Biotechnological by-product effluents: any discarded preparation made from genetically altered living organisms (excluding plants) and their products.

Managing Regulated Medical Waste

Waste Minimization

Waste minimization and pollution prevention are the first priority for managing wastes.  Waste minimization and pollution prevention is the maximum feasible reduction of the total volume of RMW generated; the reduction of the toxicity of the RMW, or both.  Practices that are considered waste minimization and pollution prevention include recycling, source separation, product substitution, and the use of less toxic materials.  All RMW generators are asked to consider performing a waste minimization and pollution prevention assessment for their facility.  An assessment involves identifying the types and amounts of RMW generated at a facility and alternative waste minimization and pollution prevention strategies for eliminating or reducing the amount or toxicity of these wastes.

Handling, Treatment and Disposal Of Regulated Medical Waste

Packaging Requirements.  Generators must comply with all U.S. Department of Transportation packaging regulations.  In addition, generators must meet the following:

  • All containers must be labeled with the name and address of the generator.
  • Containers must not be leaking when shipped.
  • Bulk containers, such as roll-off containers, are not permitted for transport of untreated RMW.

Storage Requirements.  Persons who store RMW must comply with the following requirements:

  • Waste must be stored in a manner and location that maintains the integrity of the packaging and prevents contact with water, precipitation, wind, and animals.
  • Storage areas must be locked to prevent unauthorized access.
  • Access to on-site storage areas must be limited to authorized personnel.
  • Areas used for the storage of RMW must be labeled to identify a “Universal Biohazard”.
  • Treated and non-treated RMW must be maintained such that there are no offsite odors.
  • Time limits for storage of untreated RMW, at a transfer, storage or treatment facility may not exceed three days when stored at room temperature; seven days when stored at <40 oF; or thirty-seven days when stored at <0 oF.
  • Waste received at a treatment or transfer facility must be date stamped upon receipt at the facility.

Treatment Requirements.  Persons that treat RMW must meet the following criteria:

  • Waste received at a treatment facility must be date stamped upon receipt at the facility.
  • RMW must be treated to the Treatment Standard by the following methods prior to disposal:
    • Pathological waste must be incinerated at either a certified RMW treatment facility or at a crematorium.
    • All other RMW must be autoclaved or treated by and alternative method which has been approved by the Secretary  (There are some exceptions to this requirement such as unused sharps do not require treatment and all non-hazardous chemotherapy waste must be incinerated or chemically neutralized).
  • Treatment effectiveness must be demonstrated by either challenge testing and continuous monitoring or another method with prior approval by the Secretary.
  • A Certification of Treatment must accompany all treated waste offered for disposal and must provide the following information:
    • Date treated,
    • Name and address of treatment facility,
    • Contact person,
    • Method of treatment,
    • Signature of operator or duly authorized person, certifying waste was treated to met the Treatment Standard, and
    • Method used to render waste inaccessible.

Transport Requirements.  Transporters of RMW, that meet the definition of a commercial hauler, must have a solid waste transporter permit and must ensure compliance with the packaging requirements.  Transporters must also have a Certificate of Treatment in the vehicle during transportation and must not accept boxes which show evidence of leaking.

Disposal Requirements

Once RMW has been treated to the Treatment Standard, the treated RMW may be disposed of at a certified solid waste discrete disposal facility in accordance with the requirements.  Treated sharps rendered inaccessible may be mixed in with municipal solid waste.  A Certification of Treatment must accompany all treated waste offered for disposal.  Certification of Treatment must be maintained by all in-state landfills for a period of one year.

Treatment and Transfer Facility Certification Application Requirements

Persons that wish to operate a RMW treatment or transfer facility must obtain a solid waste management facility certification as required by the Vermont Solid Waste Management Rules.

Guidance for the Proper Disposal of Home Generated Regulated Medical Waste

Home Generated RMW includes wastes generated from the use of medications, testing supplies, injectable medications and waste generated in long term care or hospice.  These wastes are purchased and administered by the resident.  Many of these wastes would be considered RMW if generated in a healthcare facility.  Proper handling and disposal methods for these wastes are critical to minimize risks to public health ad safety and to the environment.  Sharps should be placed in a hard plastic, opaque container.  Containers may be placed in the regular house hold trash.  All other medical waste, such as bandages, dressings etc. should be placed in a separate container and disposed of in the regular house hold trash.

Occupational Safety and Health (OSHA)

Vermont is one of 24 states operating an approved occupational safety and health program.  This program is operated by the Vermont's Occupational Safety and Health Administration.  OSHA rules impact several aspects of regulated medical waste, including management of sharps, requirements for containers that hold or store RMW, labeling of RMW bags/containers, and employee training.  These requirements can be found in the HERC OSHA Standards for Regulated Waste section.

More Information

In this section, you will find links to points of contacts at the Vermont agencies responsible for regulating healthcare facility waste, links to the text of the regulations, and additional resources that you might find of interest on this topic.

Contacts

Vermont Agency of Natural Resources

Statutes, Regulations and Guidelines

Solid Waste Management Rules

Additional Resources

Procedure Addressing Regulated Medical Waste Definitions and The Handling and Treatment of Regulated Medical Waste.  A document prepared by the Solid Waste Management Program, Waste Management Division, Department of Environmental Conservation Agency Of Natural Resources State Of Vermont (June, 2001).