Transcript MEDICAL WASTE MANAGEMENT - California Ambulatory …

MEDICAL WASTE
MANAGEMENT
Christine Gallagher, Surveyor
Accreditation Association for Ambulatory Health Care
Executive Director – Salinas Surgery Center
MEDICAL WASTE – Regulated by
CDPH http://www.cdph.ca.gov/certlic/medicalwaste
 BIOHAZARDOUS WASTE (aka Red bag waste)
Waste, which at the point of transport from the
generator’s site, at the point of disposal, or
thereafter, contains recognizable fluid blood, fluid
blood products or containers or equipment
containing blood that is fluid.
 Blood tubing / hemovacs / soaked bloody
dressings or sponges / suction liners with fluid
blood / OPIM
 Lab waste / specimens / cultures
 SHARPS WASTE
 Needles / broken glass vials or ampoules / blades
/ scalpels / empty syringes with needles / trochars
/ introducers / guide wires / suture needles
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MEDICAL WASTE
Pharmaceutical Waste
 (aka Blue container waste that goes in the white box) MUST BE
INCINERATED – NO INCINERATION FACILITIES IN CALIFORNIA
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Non Hazardous – all liquid medications (except
controlled substances and RCRA hazardous)
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Per Ca MWMA, Section 118280(e), Pharm
waste meeting the state definition can be held
for up to one year if less than 10 pounds is
generated per year and up to 90 days if more
than 10 pounds is generated
2 types of containers
 $$$$-one that allows sharps - syringes and
needles with residual / pourable medication
in them – this is then Medical sharps waste
and can be held only 30 days
 $-the other is liquids only – no sharps /
syringes and can be held longer
MEDICAL WASTE
Pharmaceutical Waste
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Controlled Substances –
 DEA – states that they have no current
requirements that mandate how small amounts
of narcotic waste is disposed of, the are more
concerned with it being non recoverable.
 Disposal companies or “Reverse Distributors”
 Sewer disposal of Pharmaceutical Waste
??down the drain??
 POTW – Public Owned Treatment Works
 Clean Water Act
RESOURCE CONSERVATION
AND RECOVERY ACT (RCRA)
 HAZARDOUS PHARMACEUTICAL WASTE
Ignitable / corrosive / reactive / toxic
 RCRA Hazardous (aka black container) about 8% of
pharmaceutical waste
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Certain medications / chemicals
 P Listed = Acutely Hazardous
 Epinephrine / Coumadin / Warfarin / Physostigmine
salicylate /strichnine / nicotine inhalant
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UL Listed = BULK Chemotherapy Agents
EPINEPHRINE –
 Lidocaine and other local anesthetics containing
epinephrine are NOT considered Hazardous Waste
 Also some states allow epi pens to be non hazardous
MEDICAL WASTE – OTHER
 WASTE WHICH MUST BE IDENTIFIED,
SEGREGATED AND INCINERATED
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Trace Chemotherapy Contaminated Waste
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IV Bags / vials / ampoules
Yellow Containers
Pathology Waste
NOT MEDICAL WASTE
 Urine / feces / saliva / sputum / nasal secretions / sweat / tears /
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vomitus unless it contains fluid blood.
Waste such as paper towels and paper products containing non
fluid blood
IV bags and empty bottles are regular trash if they did not
contain chemo agents or blood.
Empty vials are not sharps or biohazard unless they contained
vaccine
Dressings / chux / gloves / foley bags and drainage bags /
disposable patient items
Paper with Patient information
Compressed gas cylinders
Radioactive Waste
Fixatives and Preservatives
SMALL QUANTITY GENERATOR
LARGE QUANTITY GENERATOR
 SMALL AND LARGE QUANTITY GENERATORS
ARE REQUIRED TO REGISTER…LOCAL
ENFORCEMENT AGENCY OR CDPH
 SMALL QUANTITY GENERATOR = Medical Waste
generator, that generates less than 200 pounds per
month of medical waste.
 Must have a Medical Waste management Plan
 Have inspection every 2 years
 Keep treatment and tracking records for 3 years
 LARGE QUANTITY GENERATOR = generates 200
or more pounds of medical waste per month
 Must have a Medical Waste Management Plan
 Have inspections every year
MEDICAL WASTE MANAGEMENT
ACT - California 1991
 Established procedures for the proper
handling, storage, treatment and
transportation of medical waste.
http://www.cdph.ca.gov/certlic/medicalwaste/Do
cuments/MedicalWaste/edicalWasteManageme
ntAct.pdf
 DEFINITION: A waste product either
biohazardous or sharps waste.
 Self assessment manual
 http://www.cdph.ca.gov/certlic/medicalwaste/Docume
nts/MedicalWaste/SelfAssessmentManual.pdf
CONTAINMENT AND STORAGE
 Medical Waste shall be contained separately from
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other waste at the point of origin.
Biohazardous waste shall be labeled with the words
Biohazardous Waste or the international biohazard
symbol and the word “BIOHAZARD”.
Chemotherapeutic agents shall be confined and
placed in a secondary container with the words
“Chemotherapy Waste” or “CHEMO”.
Biohazardous Waste – Human surgery specimens or
tissues in fixatives shall be segregated and placed in
a secondary container labeled with “Pathology
Waste” or “PATH”.
STORAGE – Leak resistant / have fitting covers
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20 pounds or more per month - The generator shall not store biohazardous or
sharps waste above 32 degrees Fahrenheit for no more than 7 days
20 pounds or less – The generator shall not store biohazardous or sharps waste
above 32 degrees Fahrenheit for more than 30 days
EDUCATION AND TRAINING
 KNOW THE LAWS AND TRAIN THE STAFF
 Provide education and training
 Medical Waste Management Plan
 Types / Location of Containers
 Emergency Plan
 Signs and Labels
 Proper Disposal of Waste
 Biohazardous Waste
 Sharps
 Pharmaceuticals – Non Hazardous /
Controlled substances
VIOLATIONS AND COMMON
COMPLIANCE ISSUES
 Overfilling containers
 Not using red biohazard bags to containerize and
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store medical waste
The enclosure for the storage of medical waste is not
secure.
The enclosure for the storage of medical waste does
not have required signage.
There is an absence of adequate documentation for
any leak or spill of medical waste.
Failure to register and pay fees
Sharps waste is not being placed into a sharps
container or improperly containerized or labeled.
Failure to maintain information and tracking
documents
“CALIFORNIA ONLY” confusion
 There is confusion as to whether it is medical waste,
hazardous waste or solid waste.
 A Pharmaceutical Waste Action Group was formed at
the request of APIC for the purpose of understanding
and complying with the MWMA as it relates to
pharmaceuticals
 CDPH stated it was ok to put most in the sewer or the
trash
 Then….DHS – Environmental Branch clarified by
stating we need to abide by federal, local waste water
laws and our POTW’s regulations.
 CA law prohibits the discharge of hazardous
wastes to wastewater sewerage systems. POTW’s
have additional local authority to further restrict.
 In general, specific written permission must be obtained
from your POTW before any wastes, including
pharmaceutical wastes, are sewered.
 Although each POTW has the right to deny a request to
sewer a waste based on local conditions, the following
wastes are generally acceptable for sewering:
 Solutions in IV bags containing only saline solution,
lactate, nutrients such as glucose (e.g., D5W),
vitamins, and added salts such as potassium and/or
other electrolytes.
 The following Wastes are not acceptable for sewering:
 Any hazardous wastes, both California-only hazardous
wastes and federal hazardous wastes regulated under
RCRA.
 The following wastes may not be acceptable for sewering
if they contain materials known or suspected of being toxic
to humans, animals, aquatic life, the environment, or to
biological or other wastewater treatment processes. This
will be of particular importance for POTWs engaged in
water recycling or discharge to surface waters:
Liquid and solid pharmaceutical wastes, such as
IV bags containing biologically active materials
(e.g., antibiotics, painkillers, and antineoplastics)
and controlled substances.
 In general, medical facilities are encouraged to
reduce discharges of pharmaceuticals to the
sewer to the extent feasible. If you have any
questions about the discharge of a specific waste into
the sewerage system, please contact your local
POTW. To obtain contact information for your POTW,
check your utility or property tax bills to see who
provides your sewer service or call your city and ask
who provides sewer services in your area.
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 MEDICAL WASTE MANAGEMENT PROGRAM LOCAL
ENFORCEMENT AGENCY CONTACTS
http://www.cdph.ca.gov/certlic/medicalwaste/Documents/MedicalWaste/
L%20E%20A.pdf