Legacy Medical Waste
We are defining legacy waste as any that has been on your property for more than a year, or any that has been around for more than four months but for which you have no disposal plan. Legacy waste can be a headache for managers. The concerns arise from uncertainty as to the nature of the material and no history of what to do with the type of waste. In many cases the origin of the waste is unknown.
Steps for dealing with legacy waste:
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Figure out where it came from. If you have any records, look at those. You can also interview employees who were involved with production of the waste or who were working there at the time. Things you want to know include (1) date of generation (or period over which waste was generated), (2) activity that produced the waste, (3) any treatment or unusual storage used. Note that memories can be faulty or imprecise, especially because waste is typically not on the minds of people when it is generated. Take oral testimony with a grain of salt. If there are old written records, these are more likely to be accurate.
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Get a physical and chemical characterization. If there is any chance of radioactive materials in the waste, get a radiation measurement. Be on a lookout for properties that would make it hazardous waste.
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Estimate weight and volume.
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Determine if the legacy waste is similar to other waste you are currently generating.
If it is, decide whether you should mix the legacy waste into the current waste stream of the same sort.
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If not, determine if you can treat it on site with any on-site treatment you have.
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If not, determine if you can send it for outsite processing in a protocol/to a place you have in place.
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If needed, formulate a treatment and disposal plan.
Resolve to do better. Don’t leave legacy waste for future managers (who may be yourself.)
