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