How do you dispose of hazardous medical waste such as needles and syringes, blood soaked bandages and unused prescription drugs? Whether you choose to send regulated medical waste out to a licensed treatment and disposal facility via hauling services or mail-in services, or to purchase equipment that safely and legally neutralizes it on your premises may be determined by your state laws or what your practice or colleagues have done in the past.
Background: Medical Waste Tracking Act of 19881
The Medical Waste Tracking Act (MWTA) of 1988 was enacted after medical wastes washed up on several East Coast beaches in the 1980s, prompting a public outcry over the potential health hazards. Specifically, this act, which amended the Solid Waste Disposal Act, did the following: • Defined medical waste and established which medical wastes would be subject to program regulations. • Established a cradle-to-grave tracking system utilizing a generator-initiated tracking form. • Required management standards for segregation, packaging, labeling and marking, and storage of the medical waste. • Established record keeping requirements and penalties that could be imposed for violations.
Medical Waste Defined2
The MWTA defines medical waste as “any solid waste that is generated in the diagnosis, treatment, or immunization of human beings or animals, in research pertaining thereto, or in the production or testing of biologicals.” This definition includes, but is not limited to: • blood-soaked bandages • culture dishes and other glassware • discarded surgical gloves • discarded surgical instruments • discarded needles used to give shots or draw blood (eg, medical sharps) • cultures, stocks, swabs used to inoculate cultures • removed body organs (eg, tonsils, appendices, limbs) • discarded lancets
Hazardous Waste Generators3
A hazardous waste generator is any person or site whose processes and actions create hazardous waste. Generators are divided into three categories based upon the quantity of waste they produce. (Presumably, most dermatology practices would be considered small quantity generators.) Large Quantity Generators generate 1,000 kilograms per month or more of hazardous waste, more than 1 kilogram per month of acutely hazardous waste, or more than 100 kilograms per month of acute spill residue or soil. Small Quantity Generators generate more than 100 kilograms, but less than 1,000 kilograms, of hazardous waste per month. Conditionally Exempt Small Quantity Generators generate 100 kilograms or less per month of hazardous waste, or 1 kilogram or less per month of acutely hazardous waste, or less than 100 kilograms per month of acute spill residue or soil. Each class of generator must comply with its own set of requirements. For more information about these requirements, please see the Generator Summary Chart at www.epa.gov/osw/hazard/generation/summary.htm.4
Medical Waste Treatment Technologies
The MWTA also required EPA to look at various treatment technologies available at the time for their ability to reduce the disease-causing potential of medical waste. The technologies that EPA examined in 1990 included incinerators and autoclaves (both on site and off site); microwave units; and various chemical and mechanical systems.2
State Medical Waste Programs and Regulations5
Medical waste disposal is primarily regulated at the state level. To determine what laws apply in your state, use the map or scroll down the page for links to information about state medical waste regulations and programs at the Environmental Protection Agency site cited below in the references or by visiting www.epa.gov/osw/wyl/stateprograms.htm. See also: Model Guidelines for State Medical Waste Management at www.epa.gov/osw/nonhaz/industrial/medical/programs.htm
What Dermatologists Need to Know
Basically, hazardous waste generators — including dermatologists — have two choices: They must either process waste in-house or send the material out to a waste management treatment and disposal company. Given the hefty fines that can be imposed for violations of medical waste disposal regulations, be sure to choose a method or service that is both compliant with your state’s requirements and meets the needs of your practice.
Farming It Out
Those who ship hazardous waste off-site generally must use a certified hauler or shipper and the waste must be accompanied by a document that tracks it from generation to disposal (the hazardous waste manifest) at a facility that disposes of waste and other hazardous materials in a manner compliant with state laws. The disposal facilities, which are the ultimate destination in both cases, may in fact offer collection and transportation products and services at different price points. Hauling Services — They make it easy, but it will cost you. They typically supply — and charge for — necessary containers, which they retrieve and replace on a regular schedule, and handle all necessary documentation. Pro: Convenience/Con: Ongoing expense. Mail-In Programs — They are generally designed to transport medical waste items, which are placed in medical waste containers and shipped to a licensed disposal facility via U.S. Postal Service. Their costs typically include the selected waste container, pre-paid shipping to and from the facility, return label and destruction manifest. Pro: Less expensive than haulers/Con: Concerns about using the mail for medical waste.
Doing It Yourself
Two companies with on-site medical waste disposal machines appropriate for the typical dermatology practice are Medical Innovations, Inc.,6 and BioMedical Technology Solutions, Inc.,7 According to their product literature, both sidestep the so-called “cradle-to-grave” liability associated with medical waste, and enable you to dispose of it in their respective machines without leaving the premises, because it is neutralized to the point that it is not bound by regulations and can be disposed of like ordinary trash. Beyond their initial purchase cost, they offer significant cost savings in the long run by eliminating the need for haulers and mail-back services and might be considered “greener” as well, because waste is reduced in size thereby substantially lowering its environmental impact. Pro: Greener, no need to transport waste, long-run savings/Con: Initial outlay to purchases machines.
How do you dispose of hazardous medical waste such as needles and syringes, blood soaked bandages and unused prescription drugs? Whether you choose to send regulated medical waste out to a licensed treatment and disposal facility via hauling services or mail-in services, or to purchase equipment that safely and legally neutralizes it on your premises may be determined by your state laws or what your practice or colleagues have done in the past.
Background: Medical Waste Tracking Act of 19881
The Medical Waste Tracking Act (MWTA) of 1988 was enacted after medical wastes washed up on several East Coast beaches in the 1980s, prompting a public outcry over the potential health hazards. Specifically, this act, which amended the Solid Waste Disposal Act, did the following: • Defined medical waste and established which medical wastes would be subject to program regulations. • Established a cradle-to-grave tracking system utilizing a generator-initiated tracking form. • Required management standards for segregation, packaging, labeling and marking, and storage of the medical waste. • Established record keeping requirements and penalties that could be imposed for violations.
Medical Waste Defined2
The MWTA defines medical waste as “any solid waste that is generated in the diagnosis, treatment, or immunization of human beings or animals, in research pertaining thereto, or in the production or testing of biologicals.” This definition includes, but is not limited to: • blood-soaked bandages • culture dishes and other glassware • discarded surgical gloves • discarded surgical instruments • discarded needles used to give shots or draw blood (eg, medical sharps) • cultures, stocks, swabs used to inoculate cultures • removed body organs (eg, tonsils, appendices, limbs) • discarded lancets
Hazardous Waste Generators3
A hazardous waste generator is any person or site whose processes and actions create hazardous waste. Generators are divided into three categories based upon the quantity of waste they produce. (Presumably, most dermatology practices would be considered small quantity generators.) Large Quantity Generators generate 1,000 kilograms per month or more of hazardous waste, more than 1 kilogram per month of acutely hazardous waste, or more than 100 kilograms per month of acute spill residue or soil. Small Quantity Generators generate more than 100 kilograms, but less than 1,000 kilograms, of hazardous waste per month. Conditionally Exempt Small Quantity Generators generate 100 kilograms or less per month of hazardous waste, or 1 kilogram or less per month of acutely hazardous waste, or less than 100 kilograms per month of acute spill residue or soil. Each class of generator must comply with its own set of requirements. For more information about these requirements, please see the Generator Summary Chart at www.epa.gov/osw/hazard/generation/summary.htm.4
Medical Waste Treatment Technologies
The MWTA also required EPA to look at various treatment technologies available at the time for their ability to reduce the disease-causing potential of medical waste. The technologies that EPA examined in 1990 included incinerators and autoclaves (both on site and off site); microwave units; and various chemical and mechanical systems.2
State Medical Waste Programs and Regulations5
Medical waste disposal is primarily regulated at the state level. To determine what laws apply in your state, use the map or scroll down the page for links to information about state medical waste regulations and programs at the Environmental Protection Agency site cited below in the references or by visiting www.epa.gov/osw/wyl/stateprograms.htm. See also: Model Guidelines for State Medical Waste Management at www.epa.gov/osw/nonhaz/industrial/medical/programs.htm
What Dermatologists Need to Know
Basically, hazardous waste generators — including dermatologists — have two choices: They must either process waste in-house or send the material out to a waste management treatment and disposal company. Given the hefty fines that can be imposed for violations of medical waste disposal regulations, be sure to choose a method or service that is both compliant with your state’s requirements and meets the needs of your practice.
Farming It Out
Those who ship hazardous waste off-site generally must use a certified hauler or shipper and the waste must be accompanied by a document that tracks it from generation to disposal (the hazardous waste manifest) at a facility that disposes of waste and other hazardous materials in a manner compliant with state laws. The disposal facilities, which are the ultimate destination in both cases, may in fact offer collection and transportation products and services at different price points. Hauling Services — They make it easy, but it will cost you. They typically supply — and charge for — necessary containers, which they retrieve and replace on a regular schedule, and handle all necessary documentation. Pro: Convenience/Con: Ongoing expense. Mail-In Programs — They are generally designed to transport medical waste items, which are placed in medical waste containers and shipped to a licensed disposal facility via U.S. Postal Service. Their costs typically include the selected waste container, pre-paid shipping to and from the facility, return label and destruction manifest. Pro: Less expensive than haulers/Con: Concerns about using the mail for medical waste.
Doing It Yourself
Two companies with on-site medical waste disposal machines appropriate for the typical dermatology practice are Medical Innovations, Inc.,6 and BioMedical Technology Solutions, Inc.,7 According to their product literature, both sidestep the so-called “cradle-to-grave” liability associated with medical waste, and enable you to dispose of it in their respective machines without leaving the premises, because it is neutralized to the point that it is not bound by regulations and can be disposed of like ordinary trash. Beyond their initial purchase cost, they offer significant cost savings in the long run by eliminating the need for haulers and mail-back services and might be considered “greener” as well, because waste is reduced in size thereby substantially lowering its environmental impact. Pro: Greener, no need to transport waste, long-run savings/Con: Initial outlay to purchases machines.
How do you dispose of hazardous medical waste such as needles and syringes, blood soaked bandages and unused prescription drugs? Whether you choose to send regulated medical waste out to a licensed treatment and disposal facility via hauling services or mail-in services, or to purchase equipment that safely and legally neutralizes it on your premises may be determined by your state laws or what your practice or colleagues have done in the past.
Background: Medical Waste Tracking Act of 19881
The Medical Waste Tracking Act (MWTA) of 1988 was enacted after medical wastes washed up on several East Coast beaches in the 1980s, prompting a public outcry over the potential health hazards. Specifically, this act, which amended the Solid Waste Disposal Act, did the following: • Defined medical waste and established which medical wastes would be subject to program regulations. • Established a cradle-to-grave tracking system utilizing a generator-initiated tracking form. • Required management standards for segregation, packaging, labeling and marking, and storage of the medical waste. • Established record keeping requirements and penalties that could be imposed for violations.
Medical Waste Defined2
The MWTA defines medical waste as “any solid waste that is generated in the diagnosis, treatment, or immunization of human beings or animals, in research pertaining thereto, or in the production or testing of biologicals.” This definition includes, but is not limited to: • blood-soaked bandages • culture dishes and other glassware • discarded surgical gloves • discarded surgical instruments • discarded needles used to give shots or draw blood (eg, medical sharps) • cultures, stocks, swabs used to inoculate cultures • removed body organs (eg, tonsils, appendices, limbs) • discarded lancets
Hazardous Waste Generators3
A hazardous waste generator is any person or site whose processes and actions create hazardous waste. Generators are divided into three categories based upon the quantity of waste they produce. (Presumably, most dermatology practices would be considered small quantity generators.) Large Quantity Generators generate 1,000 kilograms per month or more of hazardous waste, more than 1 kilogram per month of acutely hazardous waste, or more than 100 kilograms per month of acute spill residue or soil. Small Quantity Generators generate more than 100 kilograms, but less than 1,000 kilograms, of hazardous waste per month. Conditionally Exempt Small Quantity Generators generate 100 kilograms or less per month of hazardous waste, or 1 kilogram or less per month of acutely hazardous waste, or less than 100 kilograms per month of acute spill residue or soil. Each class of generator must comply with its own set of requirements. For more information about these requirements, please see the Generator Summary Chart at www.epa.gov/osw/hazard/generation/summary.htm.4
Medical Waste Treatment Technologies
The MWTA also required EPA to look at various treatment technologies available at the time for their ability to reduce the disease-causing potential of medical waste. The technologies that EPA examined in 1990 included incinerators and autoclaves (both on site and off site); microwave units; and various chemical and mechanical systems.2
State Medical Waste Programs and Regulations5
Medical waste disposal is primarily regulated at the state level. To determine what laws apply in your state, use the map or scroll down the page for links to information about state medical waste regulations and programs at the Environmental Protection Agency site cited below in the references or by visiting www.epa.gov/osw/wyl/stateprograms.htm. See also: Model Guidelines for State Medical Waste Management at www.epa.gov/osw/nonhaz/industrial/medical/programs.htm
What Dermatologists Need to Know
Basically, hazardous waste generators — including dermatologists — have two choices: They must either process waste in-house or send the material out to a waste management treatment and disposal company. Given the hefty fines that can be imposed for violations of medical waste disposal regulations, be sure to choose a method or service that is both compliant with your state’s requirements and meets the needs of your practice.
Farming It Out
Those who ship hazardous waste off-site generally must use a certified hauler or shipper and the waste must be accompanied by a document that tracks it from generation to disposal (the hazardous waste manifest) at a facility that disposes of waste and other hazardous materials in a manner compliant with state laws. The disposal facilities, which are the ultimate destination in both cases, may in fact offer collection and transportation products and services at different price points. Hauling Services — They make it easy, but it will cost you. They typically supply — and charge for — necessary containers, which they retrieve and replace on a regular schedule, and handle all necessary documentation. Pro: Convenience/Con: Ongoing expense. Mail-In Programs — They are generally designed to transport medical waste items, which are placed in medical waste containers and shipped to a licensed disposal facility via U.S. Postal Service. Their costs typically include the selected waste container, pre-paid shipping to and from the facility, return label and destruction manifest. Pro: Less expensive than haulers/Con: Concerns about using the mail for medical waste.
Doing It Yourself
Two companies with on-site medical waste disposal machines appropriate for the typical dermatology practice are Medical Innovations, Inc.,6 and BioMedical Technology Solutions, Inc.,7 According to their product literature, both sidestep the so-called “cradle-to-grave” liability associated with medical waste, and enable you to dispose of it in their respective machines without leaving the premises, because it is neutralized to the point that it is not bound by regulations and can be disposed of like ordinary trash. Beyond their initial purchase cost, they offer significant cost savings in the long run by eliminating the need for haulers and mail-back services and might be considered “greener” as well, because waste is reduced in size thereby substantially lowering its environmental impact. Pro: Greener, no need to transport waste, long-run savings/Con: Initial outlay to purchases machines.
