Healthcare organizations that generate regulated medical waste (RMW) must package it appropriately for disposal to ensure staff, patient, and environmental safety as well as to maintain compliance with federal, state, and local regulations. While this may seem straightforward, organizations may struggle to consistently and correctly segregate, package, and dispose of RMW.
Healthcare organizations should develop clear packaging procedures and ensure that staff are aware of them and reliably follow them. The roadmap below can guide the process of creating RMW packaging procedures to develop a comprehensive and compliant approach.
Understand What RMW Is and Why Proper Waste Segregation Is Important
Before establishing RMW packaging procedures, it is important to understand what constitutes RMW. Unfortunately, there is no universal definition of RMW, and federal, state, and local definitions may vary. As such, it is important to identify applicable requirements at all levels and in different states and localities. That said, RMW is generally waste known or reasonably expected to contain a pathogen; 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. Based on that description, RMW would include biohazardous items that are saturated with liquid or semi-liquid blood or other potentially infectious materials (OPIM). Some examples may include contaminated disposable gowns, used gauze, and procedural drapes. Contaminated sharps, including used needles, scalpels, or syringes, would also qualify.
Know Which Regulating Agencies Govern RMW Disposal
Several regulatory bodies govern RMW, and depending on the agency, their focus varies. On the federal level, the Occupational Safety and Health Administration (OSHA) focuses on the risks this type of waste poses for healthcare workers. OSHA’s Bloodborne Pathogen Standard requires organizations to have policies and training that address proper biohazardous waste handling.
The Department of Transportation (DOT) governs transportation of RMW.
State and local environmental authorities and/or health departments also regulate RMW, as well as accrediting bodies such as the Joint Commission. While some requirements overlap, many do not. Therefore, it is critical when drafting RMW waste policies to identify and incorporate all applicable requirements.
Delineate Proper RMW Packaging Steps
After gathering information about the what and why of RMW disposal, organizations must address the how. The following are key steps involved in the packaging process:
- Step 1: Choose a suitable RMW container. Some examples of containers organizations can use include corrugated boxes or specially designed reusable containers to hold RMW. Corrugated boxes should be sealed on the bottom with strong packing tape. Printed text and arrows 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.
- Step 2: Line the RMW container with a biohazard bag. Be sure to use an appropriate bag designed for this purpose that is compliant with applicable federal, state, and local requirements. Not only are these bags meant to effectively contain the waste, but they also indicate by their color and labeling that the waste is biohazardous. The bag must line the inside of the receptacle, overlapping its four outer sides. Note that different states may have different requirements for bag color, thickness, and weight limitations.
- Step 3: 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, syringes, general trash, and recycling CANNOT be discarded in an RMW bag.
Sharps should be disposed of in a closed, puncture-resistant container, and pharmaceutical waste should be placed in its own designated, color-coded receptacle. Trace chemotherapy waste and pathological waste, although forms of RMW, require further segregation and should be marked for incineration (per Stericycle’s Waste Acceptance Policy.)
- Step 4: 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, do not overfill containers.
- Step 5: 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 PPE 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 can also use a zip tie or tape to secure the knot.
- Step 6: 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. 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 or returned to the health care organization.
- Step 7: Check the markings. The outer box should have appropriate labeling that meets federal, state, and local requirements. It also should include any information required by the organization’s waste hauler.
Develop and Implement Staff Training
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 to cover include what items should be segregated, how to package waste, and the risks if RMW is managed incorrectly.
Training should occur during orientation and as part of annual refresher events. Stericycle’s SteriSafe® online modules can be especially beneficial because staff can access them at their convenience and training is documented once completed.
Periodically Audit the Process to Make Sure Practice Follows Policy
Organizational leaders should observe whether staff are following defined RMW procedures. If they notice gaps, it may indicate the need for further education and training, which may include a refresher during the next staff meeting or an on-the-spot course correction to additional training offered virtually. Observing the behavior of staff is one of the best ways to correct mistakes as they happen and to form habits that promote safety and compliance.
Ensure Your Organization Has a Compliant Regulated Medical Waste Disposal Process
While good processes are essential for proper RMW disposal, a reliable waste management partner is also key. Learn more about how Stericycle can help you maintain a safe and compliant regulated medical waste program.
