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Three Things to Consider when Selecting a Regulated Medical Waste Disposal Company

By Richard L. Best Technical Director and Corporate Director OSHA Compliance

There are significant liabilities associated with the disposal of Regulated Medical Waste that apply to the generator of that waste. The safety of employees, financial penalties from fines, and a practice’s or company’s business reputation are all at stake so selecting a medical waste disposal company is a decision that should not be taken lightly.

Medical waste constitutes a United States Department of Transportation (DOT) class 6.2 hazardous material during transport.

In addition to DOT, the Occupational Safety and Health Administration (OSHA) and various state government agencies are also involved in ensuring that this type of waste is properly handled, packaged, stored, hauled, treated, and disposed. To avoid hefty fines for non-compliance, to ensure that your work associates are properly protected, and to protect the environment of your own community, therefore, it is important to make sure that your waste hauler is as equally committed to proper disposal and protecting your practice or business as you are. This article presents three important steps for selecting your medical waste hauler and disposal company.

Step 1: Be sure that your Regulated Medical Waste company knows and follows the proper regulations Asking a few simple questions can help you quickly zero in on high-quality companies. Start by asking any Regulated Medical Waste companies you’re considering if they have full time Environmental Health and Safety (EHS) staff members that focus on regulations. Confirm that their staff members are well versed in the following subjects: • DOT requirements • OSHA requirements, such as bloodborne pathogens training • State agency requirements Today’s regulations are confusing and continually changing, plus they differ by state. In some cases, they require the generator (the healthcare office) to maintain responsibility for its waste until final treatment and disposal. Using an RMW company with regulatory experts on staff can help make sure that you stay in compliance.

If you’re already using an RMW company, ask the driver who services your account what waste stream he or she is transporting and what safety protocols (such as spill control kits, etc.) are on the truck. If the driver can’t answer those questions, then he or she is not properly trained to service your facility.

Step 2: Look for RMW companies that can proactively help your facility stay compliant with medical waste handling.

A full-service RMW company will be flexible enough to meet a healthcare office’s changing needs, such as adding extra pickup days when needed. Your RMW company should also provide DOT compliant containers that fit your office’s waste stream needs. Additionally, other key services your RMW company should provide are: • RMW handling that includes waste collection through treatment to final documented disposal.

Many companies provide pick up service but not final disposal or destruction, and this limited range of services increases the potential liability risk to waste generators. A fully-integrated company can provide a higher degree of service and safety from pick-up through destruction.

Three Things to Consider for Selecting a Regulated Medical Waste Disposal Company

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• Training and support in regulatory and environmental compliance. DOT and OSHA both require specific training for people handling regulated medical waste. Understand which of these training programs are available as a complimentary service from your provider.

• Manifest and shipping documentation service. Your RMW company should be able to provide you with documentation of all your RMW shipments –– and ideally, make these documents available online where permitted by state law to do so. Federal DOT requires shippers to maintain shipping documents for two years, but some states have their own individual requirements that go beyond that requirement. Having online access to your documents and shipping records helps you quickly provide the required paperwork for any regulatory inspection.

• Disaster planning and emergency preparedness through back-up and redundancy of services and facilities. Understand what procedures and processes are in place for RMW disposal should a major disaster or crisis occur. Can your facility expect continuation of service? Are alternate service providers for transportation and destruction readily available to ensure your waste is properly handled?

Your RMW company should have a disaster recovery and contingency plan so that, in the event of an emergency, waste will not continue to accumulate at your facility. If your RMW company will have to use a back-up service and/or location in such circumstances, ask for contractual proof that your facility will continue to get the service it needs.

Step 3: Understand other key services your RMW company should provide.

Partnering with an RMW company that helps you stay on track with training requirements will not only help keep the regulators satisfied but will also decrease your employee risk at the same time. Look for RMW companies that provide: • OSHA Compliance Tools and Services. Protecting your facility and employees goes beyond Regulated Medical Waste handling. Many providers also other a suite of OSHA compliance services to provide a well rounded protection program that is simple and easy to follow. As regulatory experts, these companies can help take the guess work out of your OSHA Compliance plan. Be sure to ask about the tools and services as well as the staff dedicated to keeping the program up-to-date.

• Compliance Evaluations, if desired. Such evaluations should always be performed by a healthcare compliance safety specialist –– not a sales representative. The specialist should spend adequate time on-site observing current practices, identifying safety issues, and noting effective practices and best-practice gaps. Then he or she should identify corrective actions such as training and process changes.

• Waste Segregation Training. Properly segregating waste is the first step in an overall program to minimize Regulated Medical Waste. A good RMW company will provide services that help you properly segregate waste streams generated at your facility.

• Email Hotlines. Does your RMW company provide email “hotlines” where you can receive prompt answers to technical questions that come up? If you are wondering, for example, what container silver nitrate should be placed in, can you be sure that your waste company will provide you with the correct answer? What about HIPAA questions or OSHA related questions?

Three Things to Consider for Selecting a Regulated Medical Waste Disposal Company

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Conclusion Having knowledge of and then adhering to the regulations surrounding disposal of Regulated Medical Waste is vital for permitting healthcare offices to avoid fines, negative publicity, and, in some cases, even loss of professional licenses.

Identifying a high-value, full service company for management of your office’s or facility’s Regulated Medical Waste helps ensure compliance with federal, state, and local regulations. Partnering with such a company helps ensure that your work associates and community are also well protected from the hazards that Regulated Medical Waste present.

About the Author

Richard L. Best is Technical Director and Corporate Director OSHA Compliance for Stericycle, Inc. He holds a Certificate in Industrial Hygiene Management from Columbia Southern University and is an OSHA Authorized General Industry Trainer and a Certified Occupational Safety Specialist.

Three Things to Consider for Selecting a Regulated Medical Waste Disposal Company

Copyright © 2011 Stericycle, Inc. All rights reserved. • 3