Waste Segregation Training

Compliance with New Requirements Overview

Overview of Objective and Purpose  Regulations Impacting Proper Disposal of Streams  New Federal EPA Infectious Medical Waste Incinerator Regulation (HMIWI) Requirements  Definitions of Waste Types and Proper Disposal Methods • • Recyclable Materials • Regulated Medical waste •  Employee Training  Benefits of Proper Waste Segregation  Summary 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 Incinerator Air Quality Standards

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 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 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  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 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 , 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 http://www.envcap.org/statetools/  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

Regulated Medical Waste

 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

 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 • • 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

Regulated Medical Waste

Final Disposal: Only 3-5% of Medical waste is incinerated 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 • 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 Helpful Guidance

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