Every organization that produces medical waste needs a waste management plan. It might not be a legal requirement, but as a good management practice you need one. Even if you never read the guide after writing it, preparing it will help shape your thoughts and get your “ducks in a row” with regard to handling and storing waste. A regulatory agency may require you to have a waste management plan, and even when they do not require one, if you show them you have a plan you show good faith with regard to being a responsible business. Further, if there is ever an accident (employee exposure or release of materials or waste to the environment), a plan can help mitigate fears and finger-pointing.
Organizations that produce a small amount of homogeneous waste might need only a 3-page plan. Large hospitals need larger plans. Large organizations tend to have specialized employees and job functions. Even though the waste manager (or environmental or safety departments) might “own” the medical waste management plan, creation of the plan is an interdisciplinary process. You need input from others, including security personnel, emergency response workers, the maintenance department, radiology, pharmacy, etc.
Description of facility and operations
Where is your facility located and what is the scope of the buildings, equipment, and operations this plan encompasses? Show a diagram of your building and identify key areas dedicated to waste generating activities.
What is your main business? Why does it produce waste? Include all waste, not just regulated waste.
Explain your categories.
Waste managers have freedom in deciding what classifications to create and employ in keeping track of the waste. You have legally defined types of waste - radioactive, hazardous, etc. but you can get more granular.
Is liquid hazardous waste a separate category from solid hazardous waste? The EPA doesn’t stipulate this division but you might find it useful to collect and store it separately. Are recyclables a separate waste stream? If so, what items are allowed in this stream? Is chemotherapy waste separate?
How much waste do you produce?
Show historical records by category. If you anticipate a change in generation in the coming year, explain that and how you have provisions for storage for the additional waste, if needed.
Movement of waste within the facility
You should have a defined collection system with a process for segregating the waste at or near the point of generation. An examination room, for instance, may have a designated receptacle for potentially infectious waste. An office might have a recycle bin for paper and other municipal waste recyclables. The waste management plan should explain how and when the waste goes from the initial collection point to storage and ultimately out of the facility. Who is responsible for putting the waste into the collection system? How often are containers emptied? Where are they emptied to? Who does this?
If you can put a schedule in your plan, all the better. The schedule might be only a goal, but printing a goal has benefits and will spur you to act if your collection is not diligent enough.
The plan should describe which job functions handle waste. Many employees probably are involved in handling when the waste is first generated, but once the waste enters the collection system (first level collection), you probably want only designated maintenance or custodial personnel to move it.
Also, specify who (by name and job title) is in charge of waste once it enters the collection system. What is the job title/classification of workers who normally move the waste through the collection system?
Storage on site
How long do you keep waste on site? Break this down by category. How often does your disposal service remove it? Where is the waste kept? Show floor diagrams. Is there a process for monitoring the storage area for leaks? Do you keep it on pallets? What is the lighting in the area? How much regular foot traffic from employees does this area get? Can the disposal service easily get to it? Are forklifts able to get to the waste (if it is stored in containers requiring forklifts)?
Treatment on site
If you do any treatment on site, describe it. This includes immobilization of waste to prepare it for disposal. Even if more treatment will take place off site, you need an extensive description of the treatment that takes place in your facility. The description should include
If there is any old waste on site, what is your plan for disposing of it? Until it is dealt with, how are you keeping everyone safe?
Plans for improvements
If you are going to make progress on waste minimization (and most large facilities could make improvements), state your plans and goals. If you are going to modify your storage area or collection equipment in the near future, mention it here.
Which employees are getting training and for what functions and operational scenarios. State your
Include a list of emergency exits, wash stations, first aid kits, and fire extinguishers in the plan. If you have a separate safety plan, you can elaborate more in that plan, but a simple list is appropriate here.
Accident or Spill Plan
How are building occupants alerted to a release? Is there a building alarm? Explain procedures for closing areas so people don’t enter.
If specific employees are designated to respond to releases of problematic waste, explain who they are (by job title, and if possible, name). How are the responders notified when there has been a release? Automated phone call? Email? SMS? Walkie-talkie? How can you be reasonably sure those employees will be on shift and close enough to the spill to make an effective response?
Where are spill kits stored in the facility?
Is there a process for checking injury to responders and others in the area who may have been exposed?
Who certifies cleanup and authorizes opening of the facility after the cleanup?
What follow-up happens after a release?
How is your accident log structured? (Show a couple example entries). Who is in charge of the log?
State names, titles, phone numbers, and email addresses of employees responsible for waste management and those who should be contacted about environmental issues and accidents.
A living document
Lengthy waste management plans should be updated at least once a year. If nothing else, you can put in the latest numbers of waste produced and revised forecasts for waste going forward. If you have a large contact list, it probably needs to be updated.
Modern offices keep documents electronically. The plan should be locked down so only selected people can edit it, but everyone in the organization should be able to read it. You probably want to print a few hard copies - one for the emergency response and safety people at your facility, one for senior management, and one for the waste manager. Also, if you have a policy of openness with the public, you may wish to have a few hard copies available for when people request it.
But do I have to develop a plan for every single waste type we produce?
Yes, every waste type you normally produce should be mentioned in the plan. You should also have general procedures for waste management and hazard control and an accident contingency plan for releases, generation of unusual waste, and upswings in waste production. You should mention your commitment to safety and responsibility. Words matter and writing this stuff down can influence employees in your organization.
But we don’t treat waste here. We have a company take it away and dispose of it.
Yes, but you still create waste and still have it at your facility for some period of time. You need to show you have thought about what you do with it while you have it.
Having a reputable service provider take away your waste on a regular basis is a good management practice It shows good faith and that you are not disregarding the risks waste pose to humans and the environment.
Having a contract with a waste management company does not absolve you of all responsibility.
We already have a safety plan.
Good, but you still need a waste management plan. We are not trying to overburden you with paperwork, and the waste management plan does not need to be long or complicated. (The length and complexity will depend on your operations and what kind and quantity of waste you produce.) A safety plan complements the waste management plan but they are not the same.
What law says we need a plan?
None. A permit issued by a regulatory authority may require a plan. Even if you don’t have a special permit or have not been instructed by a government agency to develop one, you want to have one to limit your legal liability, show that you are aware and have thought about risks, and take your responsibility as a steward of waste management seriously.
Who signs off on the plan?
Again, this depends on the size and structure of your organization. In a very small organization, only the owner may need to approve it. In a large hospital you may want approval from the environmental officer, safety officer, facilities manager, and general manager.
Who gets a copy?
Your local fire and police departments probably don’t want the plan - they have enough paperwork. But you can offer it to them. Your city or county waste management authority (if there is one) might want a copy.
Some organizations may have the policy of letting members of the general public view the plan upon request. This shows good faith and may enhance your reputation among the community.
Any medical activities - indeed any human activities - are going to generate waste. Part of the waste management plan should include ways to avoid producing waste in the first place. This starts with purchasing. Try to not purchase things you don’t need. Consider buying in bulk for packaging efficiency - generally speaking larger batches come with less packaging per unit of product than smaller batches. Centralizing purchasing and inventory rather than letting each department order their own supplies can help with this effort. Also, regular practices of using all the material in a container - rather than throwing out containers with some materials left - and using the oldest batch in inventory to minimize the chances of product expiration - can help.
Related: Waste Assessments