Medical Waste and Healthcare Facility Regulations

1
Medical Waste and Healthcare Facility Regulations

• Southern California Waste Management Forum
• Barry Foose, Kaiser Permanente
• National Environmental Health and Safety
• November 4, 2009

2
Objectives

• To gain a better understanding of
• Medical waste categories
• Medical waste treatment requirements
• Potential issues/risks associated with
  segregation of waste streams

3
Healthcare Waste Streams

• Hospitals generate approximately 300,000 lbs./yr
  of medical waste.
• Medical Offices 10,000 lbs./yr.
• Impacted by
• Increased regulatory scrutiny
• Increased public environmental concerns
• Defensive waste management

4
What is not Regulated Medical Waste

• Food processing or biotechnology waste that does
  not contain an infectious agent.
• Urine, feces, saliva, sputum, nasal secretions,
  sweat, tears, or vomitus, unless it contains
  fluid blood
• Paper towels and paper products containing
  non-fluid blood.

• Hazardous waste, radioactive waste, or household
  waste, and home-generated sharps waste
• Veterinarian, agricultural, and animal livestock
  waste

5
Healthcare Waste Stream Grid
6
Medical Waste Streams

• Red Bag
• Sharps
• Suction Canisters
• Trace Chemotherapy
• Pathology
• Pharmaceutical Cal Only may include sharps

7
Segregation Essential

• Medical Waste must be segregated from solid waste
• Further segregation required according to waste
  type to ensure treatment (sterilization up to
  incineration).
• All procedures must be in facility Medical Waste
  Management Plan as well as Exposure Control Plan.
• Waste generators and internal handlers should be
  trained annually as part of their Bloodborne
  Pathogens training requirements.

8
Biohazardous Red Bag

• Defined in Medical Waste Management Act - HS
  Code 117635
• Largest volume of hospital Medical Waste Streams
• Must be rendered non-infectious before land
  filling.
• Typically sterilized on site or at treatment
  plant.
• Bloody or infectious materials from patients

9
Biohazardous Waste Issues

• Highest Risk - contamination by other higher
  category wastes
• Potential Issues
• Low level radioactive contamination from patients
  undergoing treatment.
• Red bags sometimes used as a catch all for
  paper waste.
• Dried blood
• PHI

10
Sharps

• Collected in puncture resistant containers to
  avoid sharps injuries.
• Must be treated before land filling, either on
  site or off site.
• Typically sterilized by autoclaving but can be
  incinerated.
• Issue - High risk for pharmacy contamination if
  waste not segregated.

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Suction Canister Waste

• Can be discharged to sewer with POTW approval
• Can be treated on site prior to sewer discharge
• Autoclaving on site not always effective for
  thicker walled canisters.
• DHS has communicated Quality Control process for
  treatment verification.
• If sterilization not effective, incineration
  required.

12
Pathology Waste

• Surgery specimens or tissues which have been
  fixed in formaldehyde or other fixatives
• Surgery specimens or tissues removed at surgery
  or autopsy, which are suspected being
  contaminated with infectious agents known to be
  contagious to humans.
• Waste must be incinerated.

13
Chemotherapy Waste

• Trace Chemotherapy
• Contaminated through contact
• Gloves, gowns, towels, and IV bags and attached
  tubing which are Empty.
• Must be incinerated.

14
What is the Definition of an Empty Chemo
Container?

• No material can be poured or drained from the
  container or inner liner.
• No material or waste remains that can feasibly be
  removed by scraping.

15
Pharmaceutical Wastes

• California only toxic pharmaceutical wastes to
  be disposed as Medical Waste by incineration in
  1997.
• Essentially a Universal Waste program.
• P or U listed chemo or characteristic were not
  included.
• There are 240 of these RCRA pharms but unknown
  number of Cal Pharms
• Waste must be incinerated.

16
DHS/APIC Pharmacy Task Force

• How many California Only Pharmaceuticals are
  there?
• Task Force identified top 25 waste pharms by
  volume - Kaiser collected and tested them for
  toxicity.
• Only one failed the toxicity test.
• Anyone know which one?

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No Drugs Down the Drain

• An LA County led group of Southern Cal POTWs had
  simultaneously started their No Drugs Down the
  Drain program.
• One option - internally collect all
  pharmaceuticals as Medical Waste, except those
  identified as RCRA.
• Potential Issue Pharms are generated everywhere
  throughout a hospital or medical office and often
  remain in syringes after partials are
  administered.

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Waste Minimization Activities

• Recycling of non-hazardous saline and other
  prescription bottles.
• Reusable Sharps and Pharmacy Containers
• Attention to dosage to minimize residuals.
• Sharing best practices.

19
Questions?

• Barry Foose
• Kaiser Permanente, National EHS
• Telephone [phone]
• e-mail barry.foose_at_kp.org
• or call National EHS at 626-381-3813