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Compliance with New Incineration Requirements
Waste Segregation Training
Overview of Objective and Purpose
 Regulations Impacting Proper Disposal of Waste Streams
 New Federal EPA Hospital Infectious Medical Waste
Incinerator Regulation (HMIWI) Requirements
 Definitions of Waste Types and Proper Disposal Methods
• Municipal Solid Waste
• Recyclable Materials
• Regulated Medical waste
• Hazardous waste
 Employee Training
 Benefits of Proper Waste Segregation
 Summary
Overview
Objective
 Gain a better understanding of different waste streams at your
facility and the proper segregation and disposal method for each
• Municipal Solid Waste
• Recyclable Materials
• Regulated Medical Waste
• Pharmaceutical Waste
• Hazardous Waste
Regulations Impacting
Waste Disposal
EPA
DOT
OSHA
FDA
State Regulations
EPA History and New Regulations
 In 1997 the EPA enacted new Air Quality source performance
 Standards and emission guidelines for existing hospital, medical
and infectious waste incinerators
 The heightened standards were effective April 6, 2012. They include
a “compliance window” in which increments of improvement are required
by all Hospital Infectious Medical Waste Incinerator (HMIWI) operators
until the compliance deadline of October 6, 2014
 Goal of the more stringent standard is to reduce emissions from HMIWI
by reducing the amount and type of waste which is sent for incineration
 EPA requires that all generators using incineration technology must
implement a Waste Segregation Plan and provide training and education
regarding proper waste segregation
EPA Incinerator
Air Quality Standards
Requirement under the New Law:
The owner or operator of an affected facility (Healthcare provider)
shall prepare a Waste Management Plan (WMP)
The WMP shall identify both the feasibility and the approach to separate
certain components of solid waste from the healthcare waste streams in
order to reduce the amount of toxic emissions from incinerated waste
The WMP should identify, reasonably available additional waste management
measures, taking into account the effectiveness of waste management
measures already in place, the costs of additional measures, the emissions
reductions expected to be achieved, and any other environmental or energy
impacts they might have
EPA Incinerator
Air Quality Standards
What is the impact on You – the Generator?
 New training / education requirements
for all generators who ship waste for
treatment through HMIWI
 Education must include proper
segregation of waste for incineration
 All generators using HMIWI must
have a Waste Management Plan
EPA Incinerator
Air Quality Standards
Definitions of Waste Types
and Proper Disposal Methods
 It is critical to establish your facility’s policies,
procedures and definitions for your Waste
Management Plan and be sure that all
employees are properly trained
• Municipal Solid Waste
• Recyclable Materials
• Regulated Medical Waste
• Pharmaceutical Waste
• Hazardous Waste
Municipal Solid Waste
 Paper and plastic: wrappers, packaging, boxes, office paper
 Unused medical products and supplies
 Personal Protective equipment: not worn, worn but not grossly
contaminated
• State regulations may impact definitions
 Food products and wastes
 Empty IV bags, bottles and tubing without needles or visible
contamination
 Empty non hazardous aerosol pressure cans
Recyclable Materials
 Recyclable materials are any materials which can be diverted
from landfill and used in a process to manufacture new products
• Paper and cardboard
• Plastic (various bottles)
• Beverage containers
(class, plastic, aluminum)
• Aluminum, tin, metal and steel
• Glass
• Batteries
• Wooden Pallets
Regulated Medical Waste
 Wastes generated within hospitals, clinics, labs, services
 Regulated Federally by:
• OSHA – health and safety of workers and handling and identification of
materials – Blood borne pathogens regulations 29 CFR 1910.1030
• DOT – considered a hazardous material and therefore must be
transported under the Hazardous Materials Regulations – 49 CFR 173.134
 Regulated by State Agencies:
• Health Departments
• Environmental Protection
• Department of Natural Resources
 No one regulatory body over all entities handling, transporting or treating
medical waste – it makes it complicated
 State regulations differ in definition – important to understand each state’s
requirements
http://www.envcap.org/statetools/
 Regulated Medical Waste (DOT) – a waste or reusable material
derived from the medical treatment of an animal or human,
which includes:
• Diagnosis and immunization; or
• From biomedical research which includes the
production and testing of biological products.
• Identification numbers:
 UN 3291 – Regulated Medical Waste
 UN 2814 – Infectious substances affecting humans –
Category A
 UN 2900 – Infectious substances affecting animals only –
Category A
 UN 3373 – Biological substance – Category B
Regulated Medical Waste
Regulated Medical Waste
 Typical Regulated Medical Waste generated within facilities
include:
• Blood bags
• Hemo-vacs
• Items saturated with blood or body fluid
 Blue pads
 Dressings
 Gowns and gloves
 Surgical sponges
• IV bags used to administer blood product
• IV bags with blood in the tubing
• Suction Canisters w/blood or body fluids
 These items should be placed in a red bag liner and disposed of as
regulated medical waste
Regulated Medical Waste
 Waste which is NOT RMW:
• Category A Materials
• Pharmaceutical waste
• USDA waste
• Chemicals
• Hazardous waste
• Radioactive waste
• Complete human remains
• Bulk Chemotherapy waste
• Compressed gas cylinders, canisters,
inhalers, and aerosol cans
• Any devices or solutions containing mercury
or other heavy metals
Regulated Medical Waste
 Containers should be
identified in areas either
by signage or policy
 Final packaging for disposal
must be in accordance with
Federal DOT requirements
 Final destruction method
should be selected based
on the type of waste and the
regulations for the state
(i.e. pathological waste and
trace chemotherapy sent for incineration)
Regulated Medical Waste
 General Packaging Requirements:
• There will be no identifiable release to the environment
• The effectiveness of the package is not substantially
reduced
• There will be no hazardous material residue adhering to
the outside of the package
 DOT requires bags to be able to contain a certain measure
of strength to hold its contents
 When large packaging is required use wheeled carts and
bulk outer packaging (BOP)
Regulated Medical Waste
 Outer packaging Requirements:
• Outer packaging is required to have
the following markings:
 Regulated Medical Waste, n.o.s.
 UN 3291
 The biohazard symbol
 The word BIOHAZARD
 Up Arrows
Regulated Medical Waste
Incinerate Only Waste:
 Two types of RMW require incineration
• Pathological waste
• Trace chemotherapy waste
 These two types of waste must be marked
with a special label indicating incinerate only
Typically these are yellow labels
 The yellow label will flag the haulers to
transfer this container to an incineration facility
Final Disposal: Only 3-5% of
Medical waste is incinerated
Regulated Medical Waste
Pharmaceutical Waste
Most healthcare professionals understand where
they need to put the medical waste and
chemotherapy but do not have proper training on
pharmaceuticals and hazardous waste
Pharmaceutical Waste
 Approximately 92% of most
pharmaceutical wastes are
non-RCRA
 RCRA hazardous pharmaceuticals
must be segregated for hazardous
waste disposal
 Best Practice for non-RCRA is
proper segregation and disposal
by incineration
 Some states have state specific
pharmaceutical regulations
which must be adhered to
Hazardous Waste
 Hazardous waste is regulated by Environmental Protection
Agency Federally and many states have additional
regulations
 Hazardous waste includes such items as chemicals,
solvents, batteries, mercury, or any item listed as a
hazardous substance on its Material Safety Data Sheet
(MSDS)
 If you are uncertain if a waste is classified as hazardous
contact your immediate supervisor or safety officer
 Never place hazardous waste into a municipal solid waste
or regulated medical waste containers
Hazardous Waste
 Hazard Communication training is required for those who work
with chemicals or other hazardous materials
 Hazardous waste requires special disposal. If you work in an area
that generates hazardous waste contact you immediate supervisor
for proper disposal techniques
 Annual Hazard Communication training will also inform you of
how to handle a spill and who to contact in emergency situations
 Some examples of hazardous waste generated at your
hospital include:
• Xylene
• Formalin
• Batteries
• Used oils
Employee Training
 Training is an important and mandatory part of being a hazmat employer
 Federal DOT requires all employees handling or signing the
manifest/shipping papers to be trained in the following:
• General Awareness
• Function Specific
• Safety
• Security
 EPA and OSHA require training for employees who handle hazardous
materials or hazardous waste
 Proper training for employees ensure they are responsible for the waste
they dispose of and properly segregate which also reduces disposal costs
Benefits of Proper
Waste Segregation
 Protects employees, patients and waste workers
 Environmentally sound
 Reduces liability for the organization
 Cost:
• Municipal Solid waste cost is the least expensive
• Recycling may or may not have a cost, depends upon
market conditions
• Hazardous waste and energy waste is the most
expensive
Summary
 Many options for waste disposal
 Identify your waste streams and definitions; communicate
with your employees
 Identify proper disposal options for those waste streams
and implement as part of your Waste Management Plan
 No one set of regulations exist for regulated medical waste
and other waste streams; be familiar with state regulations
 Properly package waste to ensure safety and compliance
KNOW THE LAW!!
Helpful Guidance
Helpful guidance on the new regulations, on waste
segregation, WAP, Waste Mgmt Plan, etc
 Analyze your total mix of waste types
 Identify Regulated Medical Waste designated for incineration
which could be reduced
 Facilitate training on proper waste segregation
 Share best practices
 Conduct audits to ensure adoption and compliance
 Provide posters illustrating proper packaging of incinerate only waste
 Work directly with the staff who packages the waste for
shipment to ensure compliance
 Provide reports tracking your progress
 Provide additional guidance available through MyStericycle.com
Helpful Guidance
Waste that must be identified and segregated for incineration
 Trace Chemotherapy Contaminated Waste - RCRA Empty drug vials, syringes and
needles, spill kits, IV tubing and bags, contaminated gloves and gowns, and
related materials as defined in applicable laws, rules, regulations or guidelines
 Pathological Waste - Human or animal body parts, organs, tissues and surgical
specimen (decanted of formaldehyde, formalin or other preservatives as required
per hazardous waste rules). Excludes complete humans remains (including heads,
full torsos, and fetuses)
 Non-RCRA Pharmaceuticals - Must be characterized and certified as
non-RCRA hazardous material by the generator. Excludes all DEA scheduled drugs,
including controlled substance *
 CALIFORNIA ONLY - Solidified Suction Canisters - Suction canisters that have been
injected with solidifier materials to control liquids or suction canisters made of
high heat resistant plastics such as polysulfone
*Consult Stericycle Representative for specific requirements
Help is Here!
 Look to MyStericycle.com for Waste Segregation Training
 Look to MyStericycle.com for a template for your Waste
Management Plan
 Contact your local representative for additional help
or regulatory updates
 Remember you can always refer to the EPA website
http://www.epa.gov/ttn/atw/129/hmiwi/rihmiwi.html
Helpful Guidance

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Segregation Training_New Incineration Requirements (10-12).pdf

  • 1. Compliance with New Incineration Requirements Waste Segregation Training
  • 2. Overview of Objective and Purpose  Regulations Impacting Proper Disposal of Waste Streams  New Federal EPA Hospital Infectious Medical Waste Incinerator Regulation (HMIWI) Requirements  Definitions of Waste Types and Proper Disposal Methods • Municipal Solid Waste • Recyclable Materials • Regulated Medical waste • Hazardous waste  Employee Training  Benefits of Proper Waste Segregation  Summary Overview
  • 3. Objective  Gain a better understanding of different waste streams at your facility and the proper segregation and disposal method for each • Municipal Solid Waste • Recyclable Materials • Regulated Medical Waste • Pharmaceutical Waste • Hazardous Waste
  • 5. EPA History and New Regulations  In 1997 the EPA enacted new Air Quality source performance  Standards and emission guidelines for existing hospital, medical and infectious waste incinerators  The heightened standards were effective April 6, 2012. They include a “compliance window” in which increments of improvement are required by all Hospital Infectious Medical Waste Incinerator (HMIWI) operators until the compliance deadline of October 6, 2014  Goal of the more stringent standard is to reduce emissions from HMIWI by reducing the amount and type of waste which is sent for incineration  EPA requires that all generators using incineration technology must implement a Waste Segregation Plan and provide training and education regarding proper waste segregation EPA Incinerator Air Quality Standards
  • 6. Requirement under the New Law: The owner or operator of an affected facility (Healthcare provider) shall prepare a Waste Management Plan (WMP) The WMP shall identify both the feasibility and the approach to separate certain components of solid waste from the healthcare waste streams in order to reduce the amount of toxic emissions from incinerated waste The WMP should identify, reasonably available additional waste management measures, taking into account the effectiveness of waste management measures already in place, the costs of additional measures, the emissions reductions expected to be achieved, and any other environmental or energy impacts they might have EPA Incinerator Air Quality Standards
  • 7. What is the impact on You – the Generator?  New training / education requirements for all generators who ship waste for treatment through HMIWI  Education must include proper segregation of waste for incineration  All generators using HMIWI must have a Waste Management Plan EPA Incinerator Air Quality Standards
  • 8. Definitions of Waste Types and Proper Disposal Methods  It is critical to establish your facility’s policies, procedures and definitions for your Waste Management Plan and be sure that all employees are properly trained • Municipal Solid Waste • Recyclable Materials • Regulated Medical Waste • Pharmaceutical Waste • Hazardous Waste
  • 9. Municipal Solid Waste  Paper and plastic: wrappers, packaging, boxes, office paper  Unused medical products and supplies  Personal Protective equipment: not worn, worn but not grossly contaminated • State regulations may impact definitions  Food products and wastes  Empty IV bags, bottles and tubing without needles or visible contamination  Empty non hazardous aerosol pressure cans
  • 10. Recyclable Materials  Recyclable materials are any materials which can be diverted from landfill and used in a process to manufacture new products • Paper and cardboard • Plastic (various bottles) • Beverage containers (class, plastic, aluminum) • Aluminum, tin, metal and steel • Glass • Batteries • Wooden Pallets
  • 11. Regulated Medical Waste  Wastes generated within hospitals, clinics, labs, services  Regulated Federally by: • OSHA – health and safety of workers and handling and identification of materials – Blood borne pathogens regulations 29 CFR 1910.1030 • DOT – considered a hazardous material and therefore must be transported under the Hazardous Materials Regulations – 49 CFR 173.134  Regulated by State Agencies: • Health Departments • Environmental Protection • Department of Natural Resources  No one regulatory body over all entities handling, transporting or treating medical waste – it makes it complicated  State regulations differ in definition – important to understand each state’s requirements http://www.envcap.org/statetools/
  • 12.  Regulated Medical Waste (DOT) – a waste or reusable material derived from the medical treatment of an animal or human, which includes: • Diagnosis and immunization; or • From biomedical research which includes the production and testing of biological products. • Identification numbers:  UN 3291 – Regulated Medical Waste  UN 2814 – Infectious substances affecting humans – Category A  UN 2900 – Infectious substances affecting animals only – Category A  UN 3373 – Biological substance – Category B Regulated Medical Waste
  • 13. Regulated Medical Waste  Typical Regulated Medical Waste generated within facilities include: • Blood bags • Hemo-vacs • Items saturated with blood or body fluid  Blue pads  Dressings  Gowns and gloves  Surgical sponges • IV bags used to administer blood product • IV bags with blood in the tubing • Suction Canisters w/blood or body fluids  These items should be placed in a red bag liner and disposed of as regulated medical waste
  • 14. Regulated Medical Waste  Waste which is NOT RMW: • Category A Materials • Pharmaceutical waste • USDA waste • Chemicals • Hazardous waste • Radioactive waste • Complete human remains • Bulk Chemotherapy waste • Compressed gas cylinders, canisters, inhalers, and aerosol cans • Any devices or solutions containing mercury or other heavy metals
  • 15. Regulated Medical Waste  Containers should be identified in areas either by signage or policy  Final packaging for disposal must be in accordance with Federal DOT requirements  Final destruction method should be selected based on the type of waste and the regulations for the state (i.e. pathological waste and trace chemotherapy sent for incineration)
  • 16. Regulated Medical Waste  General Packaging Requirements: • There will be no identifiable release to the environment • The effectiveness of the package is not substantially reduced • There will be no hazardous material residue adhering to the outside of the package  DOT requires bags to be able to contain a certain measure of strength to hold its contents  When large packaging is required use wheeled carts and bulk outer packaging (BOP)
  • 17. Regulated Medical Waste  Outer packaging Requirements: • Outer packaging is required to have the following markings:  Regulated Medical Waste, n.o.s.  UN 3291  The biohazard symbol  The word BIOHAZARD  Up Arrows
  • 18. Regulated Medical Waste Incinerate Only Waste:  Two types of RMW require incineration • Pathological waste • Trace chemotherapy waste  These two types of waste must be marked with a special label indicating incinerate only Typically these are yellow labels  The yellow label will flag the haulers to transfer this container to an incineration facility
  • 19. Final Disposal: Only 3-5% of Medical waste is incinerated Regulated Medical Waste
  • 20. Pharmaceutical Waste Most healthcare professionals understand where they need to put the medical waste and chemotherapy but do not have proper training on pharmaceuticals and hazardous waste
  • 21. Pharmaceutical Waste  Approximately 92% of most pharmaceutical wastes are non-RCRA  RCRA hazardous pharmaceuticals must be segregated for hazardous waste disposal  Best Practice for non-RCRA is proper segregation and disposal by incineration  Some states have state specific pharmaceutical regulations which must be adhered to
  • 22. Hazardous Waste  Hazardous waste is regulated by Environmental Protection Agency Federally and many states have additional regulations  Hazardous waste includes such items as chemicals, solvents, batteries, mercury, or any item listed as a hazardous substance on its Material Safety Data Sheet (MSDS)  If you are uncertain if a waste is classified as hazardous contact your immediate supervisor or safety officer  Never place hazardous waste into a municipal solid waste or regulated medical waste containers
  • 23. Hazardous Waste  Hazard Communication training is required for those who work with chemicals or other hazardous materials  Hazardous waste requires special disposal. If you work in an area that generates hazardous waste contact you immediate supervisor for proper disposal techniques  Annual Hazard Communication training will also inform you of how to handle a spill and who to contact in emergency situations  Some examples of hazardous waste generated at your hospital include: • Xylene • Formalin • Batteries • Used oils
  • 24. Employee Training  Training is an important and mandatory part of being a hazmat employer  Federal DOT requires all employees handling or signing the manifest/shipping papers to be trained in the following: • General Awareness • Function Specific • Safety • Security  EPA and OSHA require training for employees who handle hazardous materials or hazardous waste  Proper training for employees ensure they are responsible for the waste they dispose of and properly segregate which also reduces disposal costs
  • 25. Benefits of Proper Waste Segregation  Protects employees, patients and waste workers  Environmentally sound  Reduces liability for the organization  Cost: • Municipal Solid waste cost is the least expensive • Recycling may or may not have a cost, depends upon market conditions • Hazardous waste and energy waste is the most expensive
  • 26. Summary  Many options for waste disposal  Identify your waste streams and definitions; communicate with your employees  Identify proper disposal options for those waste streams and implement as part of your Waste Management Plan  No one set of regulations exist for regulated medical waste and other waste streams; be familiar with state regulations  Properly package waste to ensure safety and compliance KNOW THE LAW!!
  • 27. Helpful Guidance Helpful guidance on the new regulations, on waste segregation, WAP, Waste Mgmt Plan, etc  Analyze your total mix of waste types  Identify Regulated Medical Waste designated for incineration which could be reduced  Facilitate training on proper waste segregation  Share best practices  Conduct audits to ensure adoption and compliance  Provide posters illustrating proper packaging of incinerate only waste  Work directly with the staff who packages the waste for shipment to ensure compliance  Provide reports tracking your progress  Provide additional guidance available through MyStericycle.com
  • 28. Helpful Guidance Waste that must be identified and segregated for incineration  Trace Chemotherapy Contaminated Waste - RCRA Empty drug vials, syringes and needles, spill kits, IV tubing and bags, contaminated gloves and gowns, and related materials as defined in applicable laws, rules, regulations or guidelines  Pathological Waste - Human or animal body parts, organs, tissues and surgical specimen (decanted of formaldehyde, formalin or other preservatives as required per hazardous waste rules). Excludes complete humans remains (including heads, full torsos, and fetuses)  Non-RCRA Pharmaceuticals - Must be characterized and certified as non-RCRA hazardous material by the generator. Excludes all DEA scheduled drugs, including controlled substance *  CALIFORNIA ONLY - Solidified Suction Canisters - Suction canisters that have been injected with solidifier materials to control liquids or suction canisters made of high heat resistant plastics such as polysulfone *Consult Stericycle Representative for specific requirements
  • 29. Help is Here!  Look to MyStericycle.com for Waste Segregation Training  Look to MyStericycle.com for a template for your Waste Management Plan  Contact your local representative for additional help or regulatory updates  Remember you can always refer to the EPA website http://www.epa.gov/ttn/atw/129/hmiwi/rihmiwi.html Helpful Guidance