Dimensions of Medical Waste Management

How many waste categories?

This is a judgement call. More categories results in the waste within each category being more homogeneous and offers more potential for reducing costs in treatment and disposal. But past a certain point there are diminishing returns. The downsides include too many containers, too much cognitive load on the employees (in the segregation), and too many opportunities for accidental cross-contamination.

For legal reasons, you should have separate streams for

  • Rad waste
  • RCRA waste (hazardous waste)

If you normally generate these types.

And for economic (cost-saving) reasons you should have separate streams for

  • Biohazardous waste
  • Pharmaceutical waste
  • General non-hazardous waste - MSW

Some other potential streams (evaluate for your facility):

  • Recyclables
  • Compostables
  • Any special waste you generate that merits a separate stream.

Materials flow - Inventory Systems as an Aid to Waste Management

If you keep track of what comes into your facility, and keep track of where it goes inside the facility, you can have a more robust assessment of your waste. This is an internal management project and effort and not directly to waste identification but it helps.

To protect worker safety and be kosher with OSHA every facility should keep a list of NIOSH hazardous drugs that it has on site. This list should be kept up-to-day date and available through an internal IT system to the employees. When a new drug is added to the list (e.g. the pharmacy or radiology department or whatever) the waste manager should consider whether it will produce or end up as RCRA waste.

Does the federal government regulate medical waste?

No, not really. Not the same way they regulate storage and treatment of hazardous waste under the Resource Conservation and Recovery Act. The Environmental Protection Agency provides some guidance but they do not have statutory authority to regulate medical waste. At one time they did. The Medical Waste Tracking Act (MWTA) of 1988 gave the EPA power to oversee medical waste, but it expired in 1991. Even when the act was in force, the EPA ran their program in only part of the country. Now the power rests in the individual states. As a result of their efforts the EPA produced model guidelines for state management programs.

OSHA is a federal agency that touches on some medical waste if it threatens the health and safety of workers. The Department of Transportation has some regulations regarding shipping medical waste, and even the Drug Enforcement Agency sometimes gets involved if pharmaceuticals are involved. The industry organization The Joint Commission accredits hospitals.

At the state level, who regulates this waste? It differs from state to state, but it is likely that the state’s environmental agency and health departments may get involved. Contact your state government to find out more.

The processes for disposing of medical waste came under scrutiny in the 1980s after a few highly publicized incidents (e.g. medical waste washing up on beaches on the east coast of the United States). These incidents prompted the U.S. Congress to pass The Medical Waste Tracking Act of 1988 and to publish Finding the Rx for Managing Medical Waste. Although the EPA provides baseline regulations, most requirements for the treatment and disposal for medical waste are dictated by the individual states.