Regulated Medical Waste Proper Segregation Training

What we will cover:

1. What is Regulated Medical Waste 2. How to package regulated medical waste 3. Common deficiencies 4. Best Practices for cost saving opportunities

Why is this training important?

What falls under RMW waste

Regulated Medical Waste:

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Red Bag Waste

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Sharps Waste

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Pathology Waste

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Trace Chemotherapy Waste

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Non-RCRA Pharmaceutical Waste

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.

Red Bag Waste

• • • • • •

Red Bag Waste:

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

Question Time!

Is this Regulated Medical Waste?

: 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

What does the MWMA say on Containers?

(b) Biohazardous waste, except biohazardous waste as defined in subdivision (g) of Section 117635, shall be bagged in accordance with subdivision (b) of Section 118275 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 66840 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. 1. Rigid, leak resistant 2. Tight fitting covers 3. Any color but labeled with the international biohazard sign on the top and sides to viewed from any lateral direction.

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.

AUTOCLAVABLE WASTE:

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Red Bag Waste

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Sharps Waste

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STEAM

REQUIRED TREATMENTS

Incinerated Waste:

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Pathology Waste

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Trace Chemotherapy Waste

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Pharmaceutical Waste (California Only)

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

Pathological Waste

Pathological Waste: Definition:

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Human or Animal body parts, organ tissue and surgical specimens.

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Incineration Only *PRESERVATIVES MUST BE DECANTED!

Chemotherapy waste (RMW)

Chemotherapy Sharps Container or Bag: Trace-contaminated items generated in the preparation & administration of antineoplastic/cytotoxic drugs-Examples:

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Gowns

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Gloves

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Masks

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Barriers

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Needles and Syringes

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IV tubing

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Empty bags/bottles

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Empty drug vials

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Spill clean –up materials or kits

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HEPA filters from Pharmacy laminar air flow hood

Common Findings:

“We have not been fined yet.”

Y

OUR ELIABLE TOO!

EPA—Common Violations*

Standard Number

262.34(a)(2) & (3) 265.174

Standard

Generator Standards 262, 266, 268 262.23

Interim Status Standards Generator, Specific Wastes, LDR Generator Standards

40 CFR Description

Labeling of HW not done or incorrect Weekly Inspections not conducted of storage area (LQG) Improper Disposal of chemotherapy drugs Missing or improper manifesting 123.27

Parts 261-265 265.16

273 CWA State Program Requirements Hazardous Waste Management Interim Status Standards Universal Waste Improper drain disposal Improper pharmaceutical waste management Lack of or inadequate waste management training Improper universal waste management (mercury lamps/batteries/CRT’s) *Source should be State specific – EPA regulation identified are generic examples

Initial Penalties

$2,000/violation/container/ day & up $2,500 & up $8,000 $23,000 $10,000/day/violation $2,000/violation/container/ day & up $1900 & up $10,000 maximum

USDOT--Common Violations*

Standard Number

172.702

172.702

172.704

172.204

173.24(b) 173.24(b) 172.400

Standard 49 CFR Description

Training Requirements Training Requirements Training Requirements Shipping Papers Packaging requirements Packaging Requirements Package Labeling Requirements Failure to provide initial training Failure to provide recurrent training Failure to create and maintain training records Failure to sign a shipping paper Packaging leaks during conditions normal to transportation Overfillng or underfilling a container so that its effectiveness is reduced Failure to properly label a container *DOT regulation identified are generic examples

Initial Penalties

$700 to $2,800 $450 to $1,800 $800 and up $800 $9,000 $6,000 $5,000

OSHA--Common Violations *

Standard Number

1910.1200(e)(1) 1910.106(d)(2) 1910.151(c) 1910.23(c)(1) 5(a)(1) 1910.242(b) 1910.1030(c)(1) 1910.1450(e)(1) 1910.147(c)(1)

Standard 29 CFR Section

Hazard Communication Flammable and Combustible Liquids Medical Services/First Aid Guarding Floor and Wall Openings General Duty Clause Hand and Portable Powered Tools Bloodborne Pathogens Hazardous Chemicals Lockout/Tagout Written program Container and portable tank storage Eye wash facilities Railing Safe and healthful conditions Compressed air used for cleaning Exposure control plan Chemical hygiene plan Energy control procedure

Initial Penalties

$32,280 $26,260 $18,690 $17,040 $13,380 $11,550 $11,380 $9,840 $8,110 *Source should be State specific – OSHA regulation identified are generic examples

Examples of common deficiencies • Category: OSHA Observation: Hazardous Chemicals are clearly labeled.

Standard: 29 CFR 1910.1200 (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.

Container labeled • Category: California State Regulations Observations: Red bags are not properly labeled.

CALIFORNIA MWMA 118275 - 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 117635, 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.

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 261.33(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.

Findings:

• Category: OSHA Observation: Sharps containers are overfilled.

Standard: 29 CFR 1910.1030(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.

Cost Savings Opportunities:

1. Regulated Medical Waste disposal is usually 100 times to 500 times more expensive than regular trash.

2. If containers are disposable, the cost is significantly higher.

The 3Rs

• Fluid Reduction Policy • Create Policy for: • Urine Containers • IV Bags • Eliminate Red containers in determined areas • Utilize Green Team to: • Seek out Recycling Opportunities • Blue Wrap • Metal Surgical Items • Plastic and containers • 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