If you have employees and you might have medical waste, you need to train your people.. Medical waste issues are not intuitive and even intelligent workers will not intuitively know how to segregate and store waste. Doctors and nurses may know a lot about the human body, but they do not automatically understand waste risks and preferred handling procedures.
The extent and content of the training must depend on the complexity of the waste management program at your facility. The more categories of waste you have and the more diverse your methods of generation and the more heterogeneous your waste, the more extensive your training program needs to be.
Large facilities have specialized staffs and thus the need for training according to job function and location. For instance, in a hospital radiology section, all employees need to be trained on handling of radioactive waste. Employees in the maternity ward probably do not have to be trained for rad waste. It is the job of the waste manager to decide which job categories get trained in which areas.
You can go deep down a training rabbit hole so be careful not to overdo it. But it is a needed
We recommend a general training for all employees, even those with desk jobs who do not ordinarily deal with clinical matters. This includes:
This training can be part of or combined with general safety training, if you offer that, too.
This teaches employees about the nature of isotopes your facility has, how radioactive the materials are, including metrics for measuring radiation levels.
Also included should be
If your operation exposes employees to human blood, you have to adhere to OSHA’s Bloodbourne Pathogens Standard. OSHA requires you keep a record of employee training, including dates and names and qualifications of trainers. (OSHA says the trainers can be "infection control practitioners, nurse practitioners, and registered nurses" and sometimes industrial hygienists and epidemiologists.) You need to retain these records for at least three years.
OSHA requires you identify every employee who might be exposed to blood, blood-contaminated waste, and OPIM (other potentially infectious material) and train them in how to stay safe. You also have to keep a medical record of these employees and proof of vaccination against hepatitis B.
You have to offer the hepatitis B vaccine to all employees free of charge.
OSHA’s Bloodbourne Pathogens Standard requires facilities develop a written exposure control plan to show they have plans and practices in place to protect workers from exposure to blood and other potentially infectious fluids.
OSHA’s website has a model plan https://www.osha.gov/Publications/osha3186.html The American Safety Council also has a model plan: https://www.americansafetycouncil.com/osha/pdfs/SampleExposureControlPlan.pdf
You can customize your plan from these models. The plan has to be a living document and OSHA requires you to revisit it every year. The plan must be available to at-risk employees and you have to train relevant employees in practices to control exposure. The exposure control plan can be part of the larger facility safety plan which all hospitals, research labs, and similar facilities should have.
OSHA has rules on the qualifications of people who give training about workplace safety, and these apply to whoever does your safety training. Waste management training is not usually so codified. Your waste permit may stipulate otherwise but in these cases it is usually the case that the facility manager states their training plan when they apply for the permit. Show good faith and good intentions and you aren’t trying to skimp on training and you are probably going to get that training plan approved. Our suggestions for trainer qualifications:
New employees need to get trained within their first month on the job. This should include the general waste management training that all personnel receive and any specific training for the job or area the employee will be working in.
Different people learn in different ways, and most learn faster if they get the same information in more than one media. Classroom lectures, onsite demonstration, powerpoints, discussions all work. “Case studies” are also useful: detailed stories of waste problems faced by (real or hypothetical) employees are your facility. Most instructors find it useful to break up the day with activities.
If you get an outside trainer, they typically want the students full time for a certain block of time. For OSHA training, this can be 40 hours - so the whole work week is consumed. People tend to learn better with breaks. If you need to give them 4 hours of training, consider 2 hours one day and then another 2 hours a couple days later. They will learn better that way.
Written tests are also useful. Your employees may roll their eyes, but there are benefits to a quiz, if only to motivate them to memorize the waste categories and the collection system you have established. You can run your training any way you want - regulatory agencies will probably not object if you seem to be making a good faith effort. Tests are useful.
We recommend regular refresher training every six months, or after a major change in how waste is collected and stored. Customize to your situation. Large facilities with multiple waste categories require more training than Mom-and-Pop businesses with one kind of waste.
Training should remind employees of the hazards posed by the waste and the waste categories your facility is using. Also, the types (and color) of containers used for different waste categories, where the collection containers are, and schedule for emptying the containers.
When chemicals are used in the workplace, good operating practices include making a Material Safety Data Sheet available in the area. Sellers of chemicals generally have them available for customers and you can find MSDSs on the internet.
Wastes are less homogeneous than chemicals or chemical products such as cleaning fluids. Your waste may be unique to your process and facility.
We recommend making something like an MSDS for regularly produced waste should be available to employees. This sheet can include anticipated physical hazards (e.g. pH, ignitability), biological hazards (e.g. skin sensitivity, carcinogenicity), and environmental hazards. Print out sheets and post them in the area near the waste and make the sheets available in your internal document system. The Globally Harmonized System of Classification and Labelling of Chemicals (GHS) itemizes what should be reported for what materials.
Employees should be able to access the facilities waste management plan and any technical information about the waste that is available. Also, print emergency phone numbers on or near waste containers.