18 August 2020
Healthcare organizations that generate medical or other biohazardous waste must package it appropriately for disposal to ensure staff, patient and environmental safety, as well as maintain compliance with federal, state and local regulations. While this may seem straightforward, organizations sometimes struggle to consistently and correctly segregate, package and dispose of regulated medical waste (RMW).
Best practices involve developing clear packaging procedures and making sure staff are aware of and reliably follow them. The roadmap below can guide the process of creating procedures and yield a comprehensive and compliant approach.
The first step in establishing RMW packaging procedures is deciding what constitutes regulated medical waste. Unfortunately, there is not a universally accepted definition, and federal and state agencies have some variance on what falls within the category. That said, a good working definition is any waste that has the potential to cause infection and has regulations around its collection, transportation, treatment and disposal.
Based on that description, the RMW category would include biohazardous items that are saturated with liquid or semi-liquid blood or other potentially infectious materials (OPIM). Some examples may include contaminated disposable gowns, used gauze and procedural drapes. In addition, due to the COVID-19 public health crisis, some organizations are starting to view personal protective equipment (PPE) used when treating COVID patients as RMW.
Contaminated sharps, including used needles, scalpels or syringes, would also qualify. Sharps should be placed in specially designed, leak- and puncture-proof containers after use. These containers should also be clearly labeled biohazardous to ensure proper handling.
Once an organization determines the RMW it generates, guidelines must be created for segregating that waste. Proper segregation of RMW includes separate waste streams for biohazardous waste, sharps, pathological waste, chemotherapeutic waste and pharmaceutical waste. This ensures that each type of waste is properly disposed of and does not pose a threat to health or environmental safety.
There are several regulatory bodies concerned with RMW, and depending on the agency, their focus varies. The Occupational Safety and Health Administration (OSHA) is concerned with the risks this type of waste poses for healthcare workers. OSHA’s Bloodborne Pathogen Standard requires organizations to have policies and training that address proper biohazardous waste handling.
The Department of Transportation (DOT) is most involved with ensuring safe transportation of RMW from where it is generated to its disposal site, using incineration or autoclaving processes.
The Environmental Protection Agency (EPA) develops regulations to prevent contaminates from entering the environment, including specific requirements about where and how waste can be disposed.
Other interested parties include non-regulatory organizations such as the Joint Commission, and local and state governments, which offer rules, regulations and standards that govern the entire disposal process. While some requirements overlap, many do not. There are also variances between local, state and federal regulations. So, it is critical when drafting RMW waste policies to look at state and local requirements first because these may supersede others.
After gathering information about the what and why of RMW disposal, organizations must address the how. Following are the key steps involved in the packaging process:
Sharps should be disposed of in a closed, puncture-resistant container, and pharmaceutical waste should be placed in its own designated, color-coded receptacle. Trace chemotherapy waste and pathological waste, although forms of RMW, should be further segregated as well and marked for incineration.
Staff members that work in areas where RMW is generated should receive training on how to properly handle and dispose of contaminated materials. Similarly, staff in charge of preparing waste for pickup should receive training as well. Topics to cover include what items should be segregated, how to package waste and the risks if RMW is managed incorrectly.
Training should occur during orientation and as part of annual refresher events. Online modules can be especially beneficial because staff can access them at their convenience and training is documented once completed. If policies or procedures have changed due to COVID-19, providing refresher training upon return could be beneficial.
Organizational leaders should observe whether staff are following defined RMW procedures. If they notice lapses, it may indicate the need for further education and training. This could range from a mention in the next staff meeting to on-the-spot course correction to additional training offered virtually.
Monitoring whether employees are strictly adhering to policies and procedures is especially critical now given that some staff have been away from the daily operations they’re accustomed to. Observing the behavior of staff is one of the best ways to correct mistakes as they happen and to form habits that promote safety and compliance.
While good processes are essential for proper RMW disposal, a reliable waste management partner is also key. Learn more about how Stericycle can help you maintain a safe and compliant regulated medical waste program.
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