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