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 HERC
State-by-State Regulated Medical Waste Resource Locator
for links to more information.
percentage of your total hospital waste volume is disposed of as regulated
medical waste (RMW)? If your answer is higher than 15%, then there
is room for improvement. A comprehensive waste segregation and minimization
program can save your healthcare facility a significant amount of money while
reducing its environmental impact.
Many hospitals routinely throw from 50-70% of their waste
into the RMW stream (in your state RMW may be referred to as infectious or
biomedical waste), although a large portion of hospital waste is very similar
to that of a hotel or office building—mostly paper, cardboard and food
waste. Hospitals often pay up to 10 times as much to dispose of RMW versus
solid waste. Case studies prove that with comprehensive education, hospitals
can realistically aim to decrease RMW waste to a mere 6-10% of their waste
stream and the Centers for Disease Control (CDC) suggests that only 3-5% of
hospital waste truly needs to be disposed of as RMW.
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 Òsignificantly 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 includeon-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:
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, HERC 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):
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
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).
use by optimizing when they are replaced (i.e., don't unnecessarily remove
half full or less containers).
Use a reusable
sharps container system.
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 healthcare 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:
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 HERC 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 HERC'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 hospitals 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 hospital 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.
A paper published by the Joint Commission International argues against SUD reuse. Per the paper, reprocessing and reuse may compromise the product's performance, and the manufacturer is not liable when a product is not being used according to the manufacturer's instructions. In response to this threat, Joint Commission International accreditation standards for hospitals define very strict requirements for hospitals considering the reuse of single-use medical devices and supplies. The standards include detailed procedures, monitoring, and follow-up on adverse patient events which may be linked to this practice.