Reducing Regulated Medical Waste

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.

Waste Definitions

Hospital and other healthcare facilities generate categories of wastes; these may include:

• Common refuse

• Recyclable waste

• Non-infectious medical waste

• Regulated medical waste

• 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:

• RMW State Resource Locator (also see the VetCA section on "Definitions of Medical Waste")
• Hazardous Waste State Resource Locator
• Universal Waste State Resource Locator
• OSHA State Resource Locator

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

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.

• Cover red bag containers to reduce solid waste that is casually tossed in.

• Don't provide red bags in areas where RMW is not generated.

• Train all employees on RMW segregation.  Reinforce waste segregation as part of annual training requirements under OSHA or other routine training.

• Track RMW generation by department and hold department heads accountable for their RMW generation and disposal costs.

• Track your progress, report success and reward staff for their efforts.

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 (autoclaving),

• Microwave sterilization,

• Chemical disinfection, and

• 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.

SUD Reprocessing

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.

Additional Resources

• Association of Medical Device Reprocessors. A trade organization that provides information on technical and legislative aspects of medical device reprocessing.