1. Regulated Medical Waste Proper Segregation Training

2. What we will cover:
What is Regulated Medical Waste
How to package regulated medical waste
Common deficiencies
Best Practices for cost saving opportunities

3. Why is this training important?

4. What falls under RMW waste
Regulated Medical Waste:
Red Bag Waste
Sharps Waste
Pathology Waste
Trace Chemotherapy Waste
Non-RCRA Pharmaceutical Waste

5. What does OSHA say?
Regulated Waste" means waste that is any of the following:
(A) Contain liquid or semi-liquid blood, or are caked with dried blood or OPIM; and
(B) Are capable of releasing these materials when handled or compressed. :
(1) Liquid or semi-liquid blood or OPIM;
(2) Contaminated items that:
(3) Contaminated sharps.
(4) Pathological and microbiological wastes containing blood or OPIM.

6. Red Bag Waste Red Bag Waste: Band-aid Bloody Rag from Surgery
Blood/blood products & OPIM – Examples:
Saturated or grossly soiled disposables, I.e., bloody gauze, dressings, lap pads, OB and surgical peri-pads & gloves
Containers, catheters, or tubes with fluid blood or blood products not discarded or flushed I.e., blood sets, pliable plastic suction canisters & drainage sets (Need adequate absorbent material in container)
Dialyzers & tubing
Microbiology specimens, tubes, bottles, & devices
Blood spill clean-up materials
Band-aid
Bloody Rag from Surgery

7. Question Time!

8. Is this Regulated Medical Waste?

9. What does OSHA say on packaging? :
Disposal of Other Regulated Waste. Regulated waste not consisting of sharps shall be disposed of in containers which are:
a. Closable;
b. Constructed to contain all contents and prevent leakage during handling, storage, transport, or shipping;
c. Labeled and color-coded in accordance with subsection (g)(1)(A) of this section; and
d. Closed prior to removal to prevent spillage or protrusion of contents during handling, storage, transport, or shipping

10. What does the MWMA say on Containers?
(b) Biohazardous waste, except biohazardous waste as defined in subdivision (g) of Section , shall be bagged in accordance with subdivision (b) of Section and placed for storage, handling, or transport in a rigid container which may be disposable, reusable, or recyclable. Containers shall be leak resistant, have tight-fitting covers, and be kept clean and in good repair. Containers may be recycled with the approval of the enforcement agency. Containers may be of any color and shall be labeled with the words “Biohazardous Waste” or with the international biohazard symbol and the word “BIOHAZARD” on the lid and on the sides so as to be visible from any lateral direction. Containers meeting the requirements specified in Section of Title 22 of the California Code of Regulations, as it read on December 31, 1990, may also be used until the replacement of the containers is necessary or existing stock has been depleted.
Rigid, leak resistant
Tight fitting covers
Any color but labeled with the international biohazard sign on the top and sides to viewed from any lateral direction.

11. Sharps Waste Sharps Containers: Needles Syringes Scalpel Blades
Glass Pipettes
Slides
Lab Glassware
DOT further defines sharps to mean…
Any object that may be contaminated with an infectious substance,
and is able to cut or penetrate the skin or packaging material.

12. REQUIRED TREATMENTS Incinerated Waste: AUTOCLAVABLE WASTE:
Red Bag Waste
Sharps Waste
STEAM
Incinerated Waste:
Pathology Waste
Trace Chemotherapy Waste
Pharmaceutical Waste (California Only)
Lets talk about how we treat the waste. How many people have seen a autoclave? We own and operate our own autoclave in San Leandro. The waste is scanned at the hospital and then taken to San Leandro and scanned again then it is weighed then goes through radio active detectors and dumped into mining carts and steam sterilized at 295 degrees for 30 minutes. Then it is considered solid waste.

13. Pharmaceutical Waste Non-RCRA Pharmaceutical Waste
What goes inside the blue containers:
Partial vials (safety caps removed)
Un-dispensed, pre-instilled IV’s
Pre-filled syringes
Partial syringes
Discontinued meds
Un-administered meds
Patient prescriptions
Physician RX samples
Human surgery specimens or Tissue, Animal parts, Tissues or Carcasses

14. Pathological Waste Pathological Waste: Definition:
Human or Animal body parts, organ tissue and surgical specimens.
Incineration Only
*PRESERVATIVES MUST BE DECANTED!
Human surgery specimens or Tissue, Animal parts, Tissues or Carcasses

15. Chemotherapy waste (RMW)
Chemotherapy Sharps Container or Bag:
Trace-contaminated items generated in the preparation & administration of antineoplastic/cytotoxic drugs-Examples:
Gowns
Gloves
Masks
Barriers
Needles and Syringes
IV tubing
Empty bags/bottles
Empty drug vials
Spill clean –up materials or kits
HEPA filters from Pharmacy laminar air flow hood
Trace contaminated items generated in the preparation & administration process. We do not take Bulk chemo

16. “We have not been fined yet.”
Common Findings:
“We have not been fined yet.”
YOUR ELIABLE TOO!

17. EPA—Common Violations*
40 CFR
Standard Number
Standard
Description
Initial Penalties
262.34(a)(2) & (3)
Generator Standards
Labeling of HW not done or incorrect
$2,000/violation/container/
day & up
Interim Status Standards
Weekly Inspections not conducted of storage area (LQG)
$2,500 & up
262, 266, 268
Generator, Specific Wastes, LDR
Improper Disposal of chemotherapy drugs
$8,000
262.23
Missing or improper manifesting
$23,000
123.27
CWA State Program Requirements
Improper drain disposal
$10,000/day/violation
Parts
Hazardous Waste Management
Improper pharmaceutical waste management
$2,000/violation/container/ day & up
265.16
Lack of or inadequate waste management training
$1900 & up
273
Universal Waste
Improper universal waste management (mercury lamps/batteries/CRT’s)
$10,000 maximum
*Source should be State specific – EPA regulation identified are generic examples

18. USDOT--Common Violations*
49 CFR
Standard Number
Standard
Description
Initial Penalties
Training Requirements
Failure to provide initial training
$700 to $2,800
Failure to provide recurrent training
$450 to $1,800
Failure to create and maintain training records
$800 and up
Shipping Papers
Failure to sign a shipping paper
$800
173.24(b)
Packaging requirements
Packaging leaks during conditions normal to transportation
$9,000
Packaging Requirements
Overfillng or underfilling a container so that its effectiveness is reduced
$6,000
Package Labeling Requirements
Failure to properly label a container
$5,000
*DOT regulation identified are generic examples

19. OSHA--Common Violations *
29 CFR
Standard Number
Standard
Section
Initial Penalties
(e)(1)
Hazard Communication
Written program
$32,280
(d)(2)
Flammable and
Combustible Liquids
Container and portable tank storage
$26,260
(c)
Medical Services/First Aid
Eye wash facilities
$18,690
(c)(1)
Guarding Floor and Wall Openings
Railing
$17,040
5(a)(1)
General Duty Clause
Safe and healthful conditions
$13,380
(b)
Hand and Portable Powered Tools
Compressed air used for cleaning
$11,550
(c)(1)
Bloodborne Pathogens
Exposure control plan
$11,380
(e)(1)
Hazardous Chemicals
Chemical hygiene plan
$9,840
(c)(1)
Lockout/Tagout
Energy control procedure
$8,110
*Source should be State specific – OSHA regulation identified are generic examples

20. Examples of common deficiencies
• Category: OSHA
Observation: Hazardous Chemicals are clearly labeled.
Standard: 29 CFR (f)(6)
The employer may use signs, placards, process sheets, batch tickets, operating procedures, or other such written materials in lieu of affixing labels to individual stationary process containers, as long as the alternative method identifies the containers to which it is applicable and conveys the information required to be on a label. The written materials shall be readily accessible to the employees in their work area throughout each work shift.
Recommendation: Inspect chemical inventory.

21. Container labeled • Category: California State Regulations
Observations: Red bags are not properly labeled.
CALIFORNIA MWMA Medical Waste Segregation and Storage
To containerize or store medical waste, a person shall do all of the following:
(b) Biohazardous waste, except biohazardous waste as defined in subdivision (g) of Section , shall be placed in a red biohazard bag conspicuously labeled with the words “Biohazardous Waste” or with the international biohazard symbol and the word “BIOHAZARD.”
Recommendation: Make sure that all containers used to hold Biohazardous waste be labeled with a biohazard symbol and viewed from every lateral direction.

22. Pharmaceutical waste improperly segregated
• Category: EPA
Observation: Pharmaceutical waste is not being segregated from other waste at the point of generation.
Regulation/Standard: 40 CFR (a)-(c)
Discarded commercial chemical products, off-specification species, container residues, and spill residues thereof.
(a) Any commercial chemical product, or manufacturing chemical intermediate having the generic name listed in paragraph (e) or (f) of this section.
(b) Any off-specification commercial chemical product or manufacturing chemical intermediate which, if it met specifications, would have the generic name listed in paragraph (e) or (f) of this section.
(c) Any residue remaining in a container or in an inner liner removed from a container that has held any commercial chemical product or manufacturing chemical intermediate having the generic name listed in paragraphs (e) or (f) of this section, unless the container is empty as defined in §261.7(b) of this chapter.
Recommendation: Complete training to ensure that segregation practices are properly managed per the EPA requirements.

23. Findings: • Category: OSHA
Observation: Sharps containers are overfilled.
Standard: 29 CFR (d)(4)(iii)(A)(2)(iii) Sharps containers should be replaced routinely and not be allowed to overfill
Recommendation: Routine inspection of sharp containers should be done and containers replaced once they reach the manufacturers fill indicator level. Sharps container size should be determined by review of needs and amount of use in each area. Overfill issues should be reviewed and an increase in size of container considered when necessary.

24. Cost Savings Opportunities:
Regulated Medical Waste disposal is usually 100 times to 500 times more expensive than regular trash.
If containers are disposable, the cost is significantly higher.

25. The 3Rs Reuse Use Linen service Reusable Sharps Containers
Single Device SUD’s
Reuse Mugs and other Utensils
Dialyzer Re-use Program
Lab Glassware
External Fixate Components
Higher quality Surgery Drapes
Reduce
Fluid Reduction Policy
Create Policy for:
Urine Containers
IV Bags
Eliminate Red containers in determined areas
Recycle
Utilize Green Team to:
Seek out Recycling Opportunities
Blue Wrap
Metal Surgical Items
Plastic and containers