The Do’s and Don’ts of Packaging Liquid Regulated Medical Waste

Healthcare organizations generate a variety of regulated medical waste (RMW), including liquids. It’s important to segregate and package them properly to help keep staff, patients, and the environment safe. 

What is Regulated Medical Waste?

Regulated medical waste may include liquid or semi-liquid blood or other potentially infectious materials (OPIM); contaminated items that could release blood or other potentially infectious materials in a liquid or semi-liquid state if compressed; items that are caked with dried blood or other potentially infectious materials and can release these materials during handling; contaminated sharps; and pathological waste consisting of potentially infectious tissues (human and/or animal).​

What is a Waste Determination, and Why is it Important?

A waste determination is a conclusion about the makeup of the waste that is used to decide how it should be managed under applicable regulations. This generator responsibility helps ensure that organizational waste is handled and disposed of properly. Organizations should have policies, training, and resources that guide employees on making accurate waste determinations, which should be based upon an understanding of the processes that produce the waste. Some of the key considerations are:

• What does the waste consist of?
• Who generated the waste?
• How was the waste generated?
• Where was the waste generated?

What are Waste Acceptance Policies?

Waste acceptance policies are the requirements of a waste vendor stating what they will or will not accept and under what conditions. While these policies are designed to meet transportation and other regulatory requirements, they may also be based on operational constraints, safety, business needs, and other policy considerations of the vendor.

• After performing a waste determination, it’s important to consider the relevant regulations and review your waste vendors’ acceptance policies as some may be more stringent than others. For example, Stericycle can accept the following properly containerized liquids: body fluids around organs, contaminated fluids from dialysis, and body fluids in suction or evacuation canisters.
•  Refer to your vendor’s acceptance policy to see what will and will not be accepted. For example, Stericycle’s waste acceptance policy states that we will not take any containers that are overweight, damaged, leaking, or improperly packaged. Any liquids need to be properly containerized and sealed to prevent spilling during shipment.

How can Liquid Regulated Medical Waste be Packaged Properly?

By following appropriate RMW packaging steps for liquids, healthcare organizations can ensure it is packaged and disposed of safely.

• Choose a suitable RMW container: These include corrugated boxes or specially designed reusable containers for RMW. Corrugated boxes should be sealed in-line with packaging instructions. Printed text and arrows (required per U.S. Department of Transportation (DOT) regulations) should differentiate the receptacle’s top and bottom. Reusable containers typically do not require special set-up. For both disposable and reusable containers, appropriate marking and color-coding are required.
• Line the RMW container with a biohazard bag: Be sure to use a bag designed for this purpose that is compliant with applicable federal, state, and local requirements. These bags are meant to effectively contain the waste and indicate that it’s biohazardous by the color and labeling.  
  • The bag must line the inside of the receptacle, overlapping its four outer sides. When packaging disposal suction canisters, a solidifying agent may be required (please check with your state or local regulations) prior to closing and sealing. When packaging closed system suction containers, however, the container must be sealed, and absorbent material must be added to the red bag liner. Note that different states may have different requirements for bag color, thickness, and weight limitations.
• Place the RMW in the appropriate lined container: In addition to outlining what should go in the RMW container, it’s equally important to indicate what should not.
  • Each state has slightly different definitions of RMW, so be sure you know what can be placed in the container. Medications, loose needles or syringes, general trash, and recycling CANNOT be discarded in an RMW bag.
  • Stericycle cannot accept uncontained liquids. We can only accept containerized liquids within our boxes.
  • Sharps should be disposed of in a closed, puncture-resistant container designed specifically for managing sharps.
  • Trace chemotherapy and pathological waste, although forms of RMW, require further segregation and should be marked for incineration (per Stericycle’s Waste Acceptance Policy).
• Check the weight: Waste management partners, including Stericycle, have established weight limits for the safe handling of RMW containers. To ensure safe lifting conditions and safe disposal, please refer to your vendor’s requirements and do not overfill containers.
• Tie the bag and seal the container: Make sure there is room at the top of the bag before tying it. Staff should wear appropriate personal protective equipment as determined by your organization and applicable laws and regulations when securing the bag, gathering its edges, and twisting the top to seal the contents. Staff should then secure the bag by making a strong, hand-tied single or gooseneck knot to prevent leakage. Staff may also use a zip tie or tape to secure the knot (be sure to check your state or local regulations to ensure compliance).
• Prepare the waste for pickup: Once secured, the bag should be placed in a transport container, which should be sealed. If using a reusable transport container, staff should engage the auto-locking flaps or secure the lid depending on the receptacle design. For corrugated transport containers, staff should seal the top of the box with strong packing tape (refer to your vendor’s container closure requirements to ensure compliance with U.S. DOT regulations). Closed RMW bags should not be visible once the outer container is closed and sealed.
  • Improperly packaged waste or damaged receptacles will be denied pickup by Stericycle.
  • If you’re concerned that liquid may leak, you should add absorbent material into the red bag before placing any items that could potentially leak, ooze, spill, or drip during storage and transport. Red bags are not meant for bulk or uncontained liquids. 
• Train staff: Staff members who work in areas where RMW is generated should receive training on how to properly handle and dispose of contaminated materials. Similarly, staff in charge of preparing waste for pickup should receive training as well.
  • Topics include what items should be segregated, how to package waste, and the risks if RMW is managed incorrectly. Training should occur, at a minimum, as required per 49 CFR 172.704, in addition to any state or local requirements, and any other applicable federal law. Stericycle offers trainings and resources with our SteriSafe^® solutions. Staff can access online modules at their convenience, and training is documented once completed.

For information on how Stericycle can support your organization’s regulated waste management needs, please contact us.