How your state regulates red bag waste


Regulated medical waste (RMW) is regulated at the state level, with each state defining what material is legally considered to be RMW (also called infectious waste, biohazardous waste or special medical waste (depending on the state) within its borders. The state regulation also typically lays out the appropriate or acceptable treatment or disinfection methods for different classes of medical waste, as well as the proper storage, labeling, manifesting and disposal requirements for RMW. The agency defining RMW can vary by state but is typically the state department of health or the state environmental agency. Because finding the state definition can be challenging, organizations can use the State Medical Waste Locator Tool to identify the appropriate state definition.

Two other federal agencies also have jurisdiction relative to the management of medical waste. The US Occupational Safety and Health Administration (OSHA) Bloodborne Pathogen Standard includes federal language defining Regulated Medical Waste, upon which a growing number of state definitions are based, but primary oversight is still managed at the state level. The Department of Transportation also has guidelines that hospitals must follow relative to proper storage, transport, and labeling of medical waste.

Why is the state definition important?

Before a healthcare organization can initiate a comprehensive segregation and minimization program for RMW, it needs to understand the state and federal regulations governing the management of that waste stream. Facilities should first identify the state definition, and then create an organization-specific internal definition (based on the minimum standards of the state definition) that will then inform how it trains its clinical staff, environmental services or housekeeping staff and other employees on appropriate segregation strategies for the organization.

Internal definition

The Infection Prevention & Control Committee is the appropriate committee to create an internal definition for Regulated Medical Waste for the organization. The state regulations should be used a minimum standard for segregation, but are open to interpretation.  In order to create a comprehensive education program with which to adequately educate staffers, the committee should agree on acceptable disposal practices specific to the organization, including a review of instruments and devices used in laboratories, on patient units, the operating room, and other critical care areas.  Some may appear sharp and are not (IV spikes, for example), while others may not look sharp but are. A laboratory representative could bring in a clean example of all laboratory instruments so that the team can identify the appropriate disposal method for each item and document it clearly.  Posters with visuals of the various items can aid with education in areas like the laboratories or in the operating room.

The possibility of spreading infection is the primary concern associated with medical waste. Most microorganisms found in the environment are not particularly suited to colonizing in humans and several studies have found that most of the waste from healthcare facilities is no riskier than, say, typical household wastes. But three special categories of medical waste pose a higher potential infection risk: pathological waste, microbiological waste, and sharps.

Learn more about the types of medical waste

Safe handling

Once an internal definition of RMW is determined by the Infection Prevention & Control Committee and signed off on by Risk Management and Administration, ther organization should ensure that all employees who come into contact with RMW receive proper training on appropriate segregation techniques. Environmental services staff and all clinical staff should be trained on proper handling of all types of wastes.  Sharps and infectious material could be found in any waste stream so safety is critical for almost every employee across the organization. Just as Universal Precautions are used for safety and personal protective equipment (PPE) while aiding any patient, the same can be said for proper handling of wastes.  All waste should be transported as if it is potentially infectious.  Waste should never be pushed down or placed on a person without PPE such as coveralls or apron, gloves, and other protective equipment.  Tilt trucks or “trash trucks” can be used for transport of materials and wastes in a manner that prevents spilling or worker exposure. 

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