Whenever patients are treated or examined, medical waste is generated.
Most medical waste is not hazardous and not regulated. A medical practice generates the same type of waste and same quantity as a typical office of the same size. This is material like wastepaper, packaging materials, and food and beverage containers. This waste can be collected and disposed of in the same way that waste at other offices. In waste management circles, this is called Municipal Solid Waste (MSW). For most medical practices, over 80 percent of the waste falls into this category.
But doctors’ offices also generate biological waste material that is of concern. Some of this is classified as infectious waste or pathological waste and must be segregated and dealt with accordingly. Medical practices can generate small quantities of hazardous waste (as defined by law), too. Sharp objects used in diagnosis and treatment (e.g. needles) end up as “sharps waste.” Most doctor office facilities do not deal with radioactive materials, but the ones that do generate radioactive waste, which is a separate waste category.
Sharps waste generated at physician’s offices includes broken ampules and vials as well as needles and syringes.
Broken diagnostic instruments (old thermometers and blood pressure gauges) may have mercury in them, although the medical world is phasing these hazardous materials out. Old expired medicines and cleaning fluids can also be regulated waste that is both hazardous and subject to regulation by both OSHA (for employee safety) and the EPA (for the environment.)
Cloth materials can be contaminated with fluids from patients’ bodies, as can gloves and masks. This falls in the category of infectious waste.
Keep a separate bio waste collecting system in parallel with your non-hazardous waste (MSW) system. The non-hazardous system is like wastepaper baskets. Look at medical supplier catalogues for medical waste containers. Develop a consistent scheme for collection. The containers in each examination room should be identical so employees don’t get confused about which containers they should use for a waste. A color code system is useful. Some practices use red or yellow for all bio waste with black for MSW, and perhaps green for recyclables.
The reason you want to put as much of your waste into the MSW stream as possible is the cost of disposal is an order of magnitude lower than the cost of disposing of the hazardous waste streams.
Sharps are items that can pierce the skin and cause injury. Medical facilities are full of sharps and they are of special concern. They include syringes, scalpels, razor blades, broken glass, lancets, and needles. You need to keep sharps in their own waste stream: separate containers. You can find sharps containers in any The waste disposal company will pick up sharps if they are in a safe container.
In the US, the federal law that defines hazardous waste is called RCRA, and you see references to RCRA waste in waste management circles. State and local governments may have additional regulations for the definition, treatment, and storage of waste as "hazardous" but RCRA is what most professionals worry about when they encounter hazardous waste.
If you make some hazardous waste by serendipity, you don’t have to have a permit, but you have to dispose of the waste according to regulations. If you regularly produce waste that is classified as hazardous, your facility needs a permit from the EPA. This might sound daunting, but it is manageable and the rules for small quantity generators (SQG) (under 1000 kilograms per month) are not onerous. The EPA basically wants to make sure you are not endangering your employees, patients, or visitors, and that no hazardous waste will get out into the environment. Your waste disposal company almost certainly is experienced in hazardous waste. (If they deal with infectious/biological waste, they probably have accepted hazardous waste from other facilities).
The most important things on a day-to-day basis are
Keep your hazardous waste in secure containers and don’t mix it with other waste. Not even biological material. Shipments of hazardous waste must be tracked with a manifest system. Your waste management contractor can help you with this.
Radioactive waste is special, so ask if your waste management contractor deals with it. You don’t want it to be their first time taking rad waste. They should have a way to treat it or to turn it over to someone who can treat it for disposal. They should also be able to send the waste to a radioactive waste landfill.
This waste stream encompasses body parts and fluids, including blood, as well as materials that come into contact with biological material. Some things like saliva can be flushed down the drain, and even small amounts of blood can go down the drain as long as you have no reason to believe it will cause disease to anyone exposed to it.
Bio waste should be kept separate from regular municipal solid waste produced at the facility. The cost of disposal is typically more than 10 times as great for infectious waste. Segregating waste saves money. However, apply the precautionary principle. If there is even a trace of doubt about whether a piece of cloth or cotton has been contaminated, treat it as infectious waste. The waste management company probably charges you based on weight of waste in each category and frequency of pickup. Try to minimize waste production, but err on the side of caution. You do not want to put biological material or sharps in your MSW waste stream.
Pay attention to bodily fluids and items (plastic, cloth, paper) it gets on. Err on the side of safety and put this material into the biological waste stream. Fluids include semen, cerebrospinal fluid, amniotic fluid, and fluid from body cavities (pleural cavity, peritoneal cavity). OSHA, the federal agency that looks over worker safety has ruled that urine and feces are not in their definition of Regulated Waste unless they have blood in them, or if there is a reason to think the patient has a highly infectious disease.
You do not want to keep biological waste for more than a week, unless you keep it refrigerated. Work with your waste disposal company to establish a pickup schedule.
As controlled substances, pharmaceutical wastes must be disposed of to discourage dumpster diving and harm to animals. For expired medications, the best course is to return the drugs through a reverse distributor. If this is not feasible or if there are other reasons it cannot be done, there are techniques to make this waste unavailable. Crush pills and capsules. Mix the waste pharmaceuticals with a noxious foul-smelling material. Don’t flush medicine to the municipal sewer system except for the few medicines the FDA says should be disposed of this way.
The Department of Justice provides a handy webpage where you can find a Pharmaceutical Disposal Location in your area: https://deadiversion.usdoj.gov/drug_disposal/takeback/index.html
Every medical facility should have a waste management plan. The size and complexity depends on how many different kinds of waste are normally generated and the scope of operations. Hospital waste management plans run over 50 pages. A small doctor’s office probably can get by with a plan of 10 pages or less.
One benefit of practices or groups, is that the group can develop a single plan. That does not mean each office is absolved of responsibility for its waste, but it reduces overhead costs.
All the cool businesses are recycling these days. It can cut the cost of your MSW disposal. Check your local government and waste authority. Economics work out different in different places, but the effort your people put into recycling usually produces a monetary benefit.
It requires some effort to set up your system: separate collection bins for recyclable materials. Your local recycling authority dictates what is acceptable for the recycle stream. Paper is usually the most prevalent item. Make sure your employees know to be scrupulous about avoiding putting biological material in the recycle bins.
Your facility crew must collect the material to be recycled and avoid mixing it with other waste streams. Most facilities have an outdoor bin or dumpster for recyclables and a truck periodically comes by to empty it. Related to recycling is municipal composting, which some local governments have instituted. Food waste and landscaping waste can go to the compost stream.
Every employee at the medical practice should have some training on waste management issues. This includes clerical people who never have any clinical work whatsoever as well as doctors who think they know everything (It is often the people who think they know everything who cause the most accidents or waste incidents.)
Training should include relevant legal regulations, waste classifications and risks, safe handling of regulated and hazardous waste, warning signs, color codes used in the collection system, emergency procedures, and how to react during releases.
Few office managers like keeping significant quantities of regulated waste on site. There is a whole industry of providers who will haul away your waste if you pay them. These services provide peace of mind for a price. If they are competent, they will either treat the waste themselves or turn it over to another treatment facility, and they will ensure the waste goes to disposal.
See sample waste plan for doctors' offices.
