Reducing Regulated Medical Waste
note that this page deals with general issues. The specific requirements
that apply to your facility will depend on state and local regulations. Check
the page for your state on the VetCA
State-by-State Regulated Medical Waste Resource Locator
for links to more information.
Healthcare facilities, including veterinary clinics, often pay up to 10 times as much to dispose of regulated medical waste (RMW) versus solid waste, such as paper, cardboard and food waste. Case studies at human hospitals prove that with comprehensive education, healthcare facilities can drastically decrease their RMW volume.
The tremendous opportunities for cost and volume reductions do not come from the "gray areas" where it is difficult to determine whether the item is "significantly contaminated" or not; rather the most significant opportunities for RMW reduction come from segregating the coffee cups, packaging, paper towel waste, clean blue wrap and pizza boxes that get tossed in! In addition to proper waste segregation, other methods of RMW reduction include on-site treatment/disposal and a reduction in RMW packaging. Each of these methods is discussed here along with other related issues.
Hospital and other healthcare facilities generate categories
of wastes; these may include:
- Common refuse
- Recyclable waste
- Regulated medical
- Hazardous waste
- Universal waste
The process of segregating wastes into these categories,
thereby reducing the volume of RMW, starts with understanding the definitions
of each waste category. However, there is a complicating factor; the
definitions for each waste category, except for hazardous waste, vary from
state to state. With hazardous waste, there are minor differences between
states, but mostly states follow the federal definitions and rules. For
RMW there is an additional complicating factor; different state regulatory
agencies may define RMW differently. For example, a health and safety
agency may use a different definition than an environmental agency, even within
the same state. To help clarify this situation, VetCA has created the
following state locators:
Use these tools to develop a better understanding of waste
definitions and how wastes are regulated in your state.
Understanding these waste definitions will help you reduce
the amount of waste your facility generates. It will also help maintain
compliance. If your facility disposes of hazardous waste according to
the rules for RMW or municipal solid waste, or if you dispose of RMW according
to the rules for solid waste, you will be in violation of the law, and can
be liable for substantial penalties.
Waste segregation is usually the most effective
method of reducing RMW. In some states, it is required by law.
Overall, the strategy is simple - keep non-regulated waste
out of the RMW stream. To maximize your returns, consider the following
measures (some are mandated by environmental or health and safety regulations):
- Use separate
color-coded and labeled RMW collection containers (e.g., red
bags and sharps containers).
- Post signs at
RMW disposal locations outlining what types of waste are to be disposed
of as RMW. Use multiple languages, if necessary, for optimal communication.
- Survey the facility
to determine waste generation rates for specific areas, and provide containers
of the right size to match those needs.
- Where RMW containers
are used, also provide regular waste containers to ensure
that employees are making a conscious disposal and segregation decision.
red bag containers to reduce solid waste that is casually tossed
- Don't provide
red bags in areas where RMW is not generated.
all employees on RMW segregation. Reinforce waste segregation
as part of annual training requirements under OSHA or other routine
RMW generation by department and hold department heads accountable
for their RMW generation and disposal costs.
your progress, report success and reward staff for their
Reduce Disposal of RMW Packaging
A significant percentage of the RMW sent off-site for disposal
is packaging (e.g., bags, sharps containers); including local collection containers
and additional containers used for off-site shipment; the entire weight of
which counts as RMW. To reduce the quantity of packaging material disposed
of, consider the following:
- Size red bags
and sharps containers according to need at specific locations (i.e., smaller
bags/containers for areas with low RMW generation rates).
- Maximize container
use by optimizing when they are replaced (i.e., don't unnecessarily remove
half full or less containers).
- Use a reusable
sharps container system.
- Ship RMW
off-site in reusable containers. These may be available from your
RMW waste services provider and/or disposal facility.
On-Site Treatment and Disposal
Regulations governing on-site treatment and disposal are
highly state-specific. Investigate the rules in
your state before implementing any changes.
All states allow veterinary facilities to treat regulated
medical waste on-site when an approved method of treatment is used. Some
states require permits or operating plans for any type of treatment unit, while
other states only require air pollution permits for incineration units.
In many states, regulated medical waste that has been treated
on-site to render it non-infectious may be mixed with and disposed of with
ordinary waste when certain rules are followed. However, in other states,
you are required to keep treated medical waste segregated from other waste,
and you may have to provide written notification that must accompany the treated
waste to its disposal location.
There are a wide variety of medical waste treatment technologies
that can be used on-site. The primary methods include:
- Steam sterilization
- Microwave sterilization,
- Chemical disinfection,
- Sewer discharge
of liquids, including blood, but excluding chemical wastes (local
sanitary district approval is usually required)
Some states that require RMW be shredded or ground, in order
to render it 'unrecognizable'; some even specify the maximum size of
the shredded waste. (Check the rules for your state via the VetCA RMW
State Resources Locator.) The shredding or grinding operation can
be carried out during the disinfection process, as in rotoclave technology,
or after disinfection, using an external shredder. Historically, some
facilities had chosen to shred waste before disinfection, but there has been
concern about the volatilization of certain materials, such as TB spores, from
this process. According to currently accepted best practices, facilities
are encouraged to shred either internally or after the disinfection process.
Most states also have a process for granting permission to
use new or alternative methods of treatment. This typically involves
a petition process. Some states do not approve or recommend any specific treatment
methods, but leave it up to the generator to determine an appropriate and effective
treatment method for their wastes.
For more information see VetCA's section on RMW
Treatment and Disposal.
The reprocessing and reuse of single use devices (SUDs) is an optional healthcare facility cost-cutting practice (40 to 60% less than new devices) that also reduces the volume of regulated medical waste disposed of. The majority of SUDs reprocessed are products made from rigid, hard metals or durable polymers and plastics that can be reused between two and five times, depending on the device. Reprocessing has been regulated by the U.S. Food & Drug Administration (FDA) since 2000.
Reprocessing of single use medical devices has evolved over the past 20 to 30 years. Initially, reprocessing was performed by healthcare facilities themselves. When healthcare facilities desired reprocessing of complex products, complicated decontamination and sterilization procedures were needed. As a result, an industry of third-party reprocessors developed.
Before medical devices can be reprocessed and reused, a third-party or healthcare facility reprocessor must comply with the same requirements that apply to original equipment manufacturers, including pre-market submission requirements, plus they must meet supplementary rules, including submission of validation data.