Compliance with New Incineration Requirements
Waste Segregation Training
Overview of Objective and Purpose Regulations Impacting Proper Disposal of Waste Streams
New Federal EPA Hospital Infectious Medical Waste Incinerator Regulation (HMIWI) Requirements
Definitions of Waste Types and Proper Disposal Methods
• Municipal Solid Waste
• Recyclable Materials
• Regulated Medical waste
• Hazardous waste
Employee Training
Benefits of Proper Waste Segregation
Summary
Overview
Objective
Gain a better understanding of different waste streams at your facility and the proper segregation and disposal method for each
• Municipal Solid Waste
• Recyclable Materials
• Regulated Medical Waste
• Pharmaceutical Waste
• Hazardous Waste
Regulations Impacting Waste Disposal
EPA
DOT
OSHA
FDA
State Regulations
EPA History and New Regulations
In 1997 the EPA enacted new Air Quality source performance
Standards and emission guidelines for existing hospital, medical and infectious waste incinerators
The heightened standards were effective April 6, 2012. They include a “compliance window” in which increments of improvement are required by all Hospital Infectious Medical Waste Incinerator (HMIWI) operators until the compliance deadline of October 6, 2014
Goal of the more stringent standard is to reduce emissions from HMIWI by reducing the amount and type of waste which is sent for incineration
EPA requires that all generators using incineration technology must implement a Waste Segregation Plan and provide training and education regarding proper waste segregation
EPA Incinerator Air Quality Standards
Requirement under the New Law:
The owner or operator of an affected facility (Healthcare provider) shall prepare a Waste Management Plan (WMP) The WMP shall identify both the feasibility and the approach to separate certain components of solid waste from the healthcare waste streams in order to reduce the amount of toxic emissions from incinerated waste
The WMP should identify, reasonably available additional waste management measures, taking into account the effectiveness of waste management measures already in place, the costs of additional measures, the emissions reductions expected to be achieved, and any other environmental or energy impacts they might have
EPA Incinerator Air Quality Standards
What is the impact on You – the Generator?
New training / education requirements for all generators who ship waste for treatment through HMIWI
Education must include proper segregation of waste for incineration
All generators using HMIWI must have a Waste Management Plan
EPA Incinerator Air Quality Standards
Definitions of Waste Types and Proper Disposal Methods
It is critical to establish your facility’s policies, procedures and definitions for your Waste Management Plan and be sure that all employees are properly trained
• Municipal Solid Waste
• Recyclable Materials
• Regulated Medical Waste
• Pharmaceutical Waste
• Hazardous Waste
Municipal Solid Waste
Paper and plastic: wrappers, packaging, boxes, office paper
Unused medical products and supplies
Personal Protective equipment: not worn, worn but not grossly contaminated
• State regulations may impact definitions
Food products and wastes
Empty IV bags, bottles and tubing without needles or visible contamination
Empty non hazardous aerosol pressure cans
Recyclable Materials
Recyclable materials are any materials which can be diverted from landfill and used in a process to manufacture new products
• Paper and cardboard
• Plastic (various bottles)
• Beverage containers (class, plastic, aluminum)
• Aluminum, tin, metal and steel
• Glass
• Batteries
• Wooden Pallets
Regulated Medical Waste
Wastes generated within hospitals, clinics, labs, services
Regulated Federally by:
• OSHA – health and safety of workers and handling and identification of materials – Blood borne pathogens regulations 29 CFR 1910.1030
• DOT – considered a hazardous material and therefore must be transported under the Hazardous Materials Regulations – 49 CFR 173.134
Regulated by State Agencies:
• Health Departments
• Environmental Protection
• Department of Natural Resources
No one regulatory body over all entities handling, transporting or treating medical waste – it makes it complicated
State regulations differ in definition – important to understand each state’s requirements
http://www.envcap.org/statetools/
Regulated Medical Waste (DOT) – a waste or reusable material derived from the medical treatment of an animal or human, which includes:
• Diagnosis and immunization; or
• From biomedical research which includes the production and testing of biological products.
• Identification numbers:
UN 3291 – Regulated Medical Waste
UN 2814 – Infectious substances affecting humans – Category A
UN 2900 – Infectious substances affecting animals only – Category A
UN 3373 – Biological substance – Category B
Regulated Medical Waste
Regulated Medical Waste
Typical Regulated Medical Waste generated within facilities include:
• Blood bags • Hemo-vacs • Items saturated with blood or body fluid
Blue pads Dressings Gowns and gloves Surgical sponges
• IV bags used to administer blood product • IV bags with blood in the tubing • Suction Canisters w/blood or body fluids
These items should be placed in a red bag liner and disposed of as regulated medical waste
Regulated Medical Waste
Waste which is NOT RMW:
• Category A Materials
• Pharmaceutical waste
• USDA waste
• Chemicals
• Hazardous waste
• Radioactive waste
• Complete human remains
• Bulk Chemotherapy waste
• Compressed gas cylinders, canisters, inhalers, and aerosol cans
• Any devices or solutions containing mercury or other heavy metals
Regulated Medical Waste
Containers should be identified in areas either by signage or policy
Final packaging for disposal must be in accordance with Federal DOT requirements
Final destruction method should be selected based on the type of waste and the regulations for the state (i.e. pathological waste and trace chemotherapy sent for incineration)
Regulated Medical Waste
General Packaging Requirements:
• There will be no identifiable release to the environment
• The effectiveness of the package is not substantially reduced
• There will be no hazardous material residue adhering to the outside of the package
DOT requires bags to be able to contain a certain measure of strength to hold its contents
When large packaging is required use wheeled carts and bulk outer packaging (BOP)
Regulated Medical Waste
Outer packaging Requirements:
• Outer packaging is required to have the following markings:
Regulated Medical Waste, n.o.s.
UN 3291
The biohazard symbol
The word BIOHAZARD
Up Arrows
Regulated Medical Waste
Incinerate Only Waste:
Two types of RMW require incineration
• Pathological waste
• Trace chemotherapy waste
These two types of waste must be marked with a special label indicating incinerate only Typically these are yellow labels
The yellow label will flag the haulers to transfer this container to an incineration facility
Final Disposal: Only 3-5% of Medical waste is incinerated
Regulated Medical Waste
Pharmaceutical Waste
Most healthcare professionals understand where they need to put the medical waste and
chemotherapy but do not have proper training on pharmaceuticals and hazardous waste
Pharmaceutical Waste
Approximately 92% of most pharmaceutical wastes are non-RCRA
RCRA hazardous pharmaceuticals must be segregated for hazardous waste disposal
Best Practice for non-RCRA is proper segregation and disposal by incineration
Some states have state specific pharmaceutical regulations which must be adhered to
Hazardous Waste
Hazardous waste is regulated by Environmental Protection Agency Federally and many states have additional regulations
Hazardous waste includes such items as chemicals, solvents, batteries, mercury, or any item listed as a hazardous substance on its Material Safety Data Sheet (MSDS)
If you are uncertain if a waste is classified as hazardous contact your immediate supervisor or safety officer
Never place hazardous waste into a municipal solid waste or regulated medical waste containers
Hazardous Waste
Hazard Communication training is required for those who work with chemicals or other hazardous materials
Hazardous waste requires special disposal. If you work in an area that generates hazardous waste contact you immediate supervisor for proper disposal techniques
Annual Hazard Communication training will also inform you of how to handle a spill and who to contact in emergency situations
Some examples of hazardous waste generated at your hospital include:
• Xylene
• Formalin
• Batteries
• Used oils
Employee Training
Training is an important and mandatory part of being a hazmat employer
Federal DOT requires all employees handling or signing the manifest/shipping papers to be trained in the following:
• General Awareness
• Function Specific
• Safety
• Security
EPA and OSHA require training for employees who handle hazardous materials or hazardous waste
Proper training for employees ensure they are responsible for the waste they dispose of and properly segregate which also reduces disposal costs
Benefits of Proper Waste Segregation
Protects employees, patients and waste workers
Environmentally sound
Reduces liability for the organization
Cost:
• Municipal Solid waste cost is the least expensive
• Recycling may or may not have a cost, depends upon market conditions
• Hazardous waste and energy waste is the most expensive
Summary
Many options for waste disposal
Identify your waste streams and definitions; communicate with your employees
Identify proper disposal options for those waste streams and implement as part of your Waste Management Plan
No one set of regulations exist for regulated medical waste and other waste streams; be familiar with state regulations
Properly package waste to ensure safety and compliance
KNOW THE LAW!!
Helpful Guidance
Helpful guidance on the new regulations, on waste segregation, WAP, Waste Mgmt Plan, etc
Analyze your total mix of waste types
Identify Regulated Medical Waste designated for incineration which could be reduced
Facilitate training on proper waste segregation
Share best practices
Conduct audits to ensure adoption and compliance
Provide posters illustrating proper packaging of incinerate only waste
Work directly with the staff who packages the waste for shipment to ensure compliance
Provide reports tracking your progress
Provide additional guidance available through MyStericycle.com
Helpful Guidance
Waste that must be identified and segregated for incineration
Trace Chemotherapy Contaminated Waste - RCRA Empty drug vials, syringes and needles, spill kits, IV tubing and bags, contaminated gloves and gowns, and related materials as defined in applicable laws, rules, regulations or guidelines
Pathological Waste - Human or animal body parts, organs, tissues and surgical specimen (decanted of formaldehyde, formalin or other preservatives as required per hazardous waste rules). Excludes complete humans remains (including heads, full torsos, and fetuses)
Non-RCRA Pharmaceuticals - Must be characterized and certified as non-RCRA hazardous material by the generator. Excludes all DEA scheduled drugs, including controlled substance *
CALIFORNIA ONLY - Solidified Suction Canisters - Suction canisters that have been injected with solidifier materials to control liquids or suction canisters made of high heat resistant plastics such as polysulfone
*Consult Stericycle Representative for specific requirements
Help is Here!
Look to MyStericycle.com for Waste Segregation Training
Look to MyStericycle.com for a template for your Waste Management Plan
Contact your local representative for additional help or regulatory updates
Remember you can always refer to the EPA website http://www.epa.gov/ttn/atw/129/hmiwi/rihmiwi.html
Helpful Guidance