TENNESSEE TECH UNIVERSITY ENVIRONMENTAL HEALTH AND SAFETY (EHS) 372-3587, www.tntech.edu/safety

Regulated Medical Waste

General awareness / familiarization Function-specific training Safety training

Personal Protection

Emergency Response

Security

The U.S. Department of Transportation (DOT) regulates the transport of hazardous materials in commerce. The Hazardous Materials Regulations (HMR, Title 49 Code of Federal Regulations, Parts 171-180) set forth standards for classification, packaging, hazard communication, emergency response information, training of hazmat employees, transportation, incident reporting, and security.

There can be significant penalties imposed by the DOT for not complying

with the HMR. Penalties for Noncompliance: Compliance with HMR is mandatory and penalties are imposed for

noncompliance.

Up to $250,000 fine and up to a year jail sentence for individuals.

Up to $500,000 fine per incidence per organization.

Current DOT regulations require training (and retraining) of all employees who perform work functions covered by the HMR. Any employee who works in a shipping, receiving or material handling area may be involved in preparing or transporting hazardous materials, and if so would be considered a hazmat employee by the HMR.

“Hazmat” A substance or material that the Secretary of

Transportation has determined is capable of posing an unreasonable risk to health, safety, and property when transported in commerce, and has designated as hazardous.

The DOT training requires employees who interact in any way with hazardous materials to be able to recognize and identify those hazardous materials, have knowledge of emergency response information, self-protection measures and accident prevention methods and procedures.

A person who is employed, and in the course of such employment directly affects hazardous materials transportation safety.

If your job requires you to:

Fill a hazardous materials package Close a filled hazardous materials package or container Mark or label a package to indicate it contains a hazardous material Prepare a shipping paper Certify on the shipping manifest that a hazardous material is in proper

condition for transportation Load a hazardous material package onto a transport vehicle Operate a vehicle used to transport hazardous materials …you are a “hazmat employee”.

Several agencies have regulations that cover Regulated Medical Waste (RMW).

RMW is also called: biohazard waste, infectious medical waste, and regulated waste.

Department of Transportation (DOT)

49 CFR, subtitle B, Chapter 1, subchapter C- This set of regulations covers transport of hazardous materials over the road.

Occupational Safety & Health Administration (OSHA)

29 CFR 1910.1030 – This is the bloodborne pathogen standard (BBP). This set of regulations covers anyone handling human derived materials.

Tennessee Department of Environmental Conservation (TDEC)

Rule 1200-01-07 – These regulations cover the treatment and final disposal of RMW in a landfill.

The OSHA BBP standard covers any materials derived from humans, as they may be potentially infectious. To handle these materials or their wastes, you are required by OSHA to complete BBP training. Contact EHS for more information.

BBPs may be present in infectious concentrations in human:

• Blood (highest risk)

• Semen/Vaginal secretions

• Fluid from the spine, joints and lungs

• Any body fluid contaminated with blood

• Any body fluid that you can’t identify

…and OPIMs (other potentially infectious materials)…

OPIMs in clinical or lab settings: Human blood products (plasma, albumin, etc.). Unfixed tissue/organ, other than intact skin of human origin. Cell or tissue cultures that may contain BBPs. Organ cultures, culture medium or other solutions that may contain BBPs. Blood from experimental animals infected with BBPs. A few human derived materials are NOT considered to be a BBP hazard and do not fall under the OSHA BBP standard unless they are visibly contaminated with blood:

• Urine/ Feces

• Vomit

• Sweat/ Tears/ Spit/ Nasal secretions

However, PRACTICE Universal Precautions: Universal precautions means treating all human derived materials as if they are potentially infectious!

Hazmat employees must be trained when performing duties.

Training must be completed at least every 3 years.

Must be directly supervised by a trained person until

trained.

You can have other employees do the work of packaging the waste, provided that a trained person supervise them.

However, you cannot allow untrained personnel to sign the waste manifest, as this is an official record of our waste activities.

1 - Explosives 2 - Gases

Liquid Nitrogen

3 - Flammable liquids

Alcohol, formaldehyde

4 - Flammable solids 5 - Oxidizing substances and

Organic peroxides

6 - Toxic & infectious substances

Infectious substances- (includes RMW)

7 - Radioactive 8 - Corrosives 9 - Miscellaneous dangerous goods

Dry Ice

Genetically Modified Organisms

A hazardous material is defined as a substance or material, that when transported in commerce, is capable of posing a risk to health, safety, or property. Hazardous materials include biological, chemical, and radioactive materials. Hazardous materials are divided into one of nine hazard classes.

Regulated Medical Waste is in Class 6 (Division 6.2-Infectious Substances)

Regulated Medical Waste is in Class 6 (Division 6.2-Infectious Substances). Division 6.2 Categories include: •Infectious Substances (Category A or B) •Biological Products •Culture •Patient Specimen •Regulated Medical Wastes

6.2 Infectious Substances are materials known or reasonably expected to contain a pathogen.

Category A - capable of causing permanent disability or life-threatening or fatal disease in otherwise healthy humans or animals. Example: cultures of vertoxigenic E.coli.

Category B - generally not capable of causing such a severe disability or death. Example: Campylobacter jejuni.

Biological Products – substances used in the prevention, treatment, or cure of a disease (virus, therapeutic serum, antitoxin, vaccine, blood).

Culture – an infectious substance containing a pathogen that is intentionally propagated, does not include a human or animal patient specimen.

Patient Specimen - human or animal material directly collected and transported for research, diagnosis, investigational activities, or disease treatment or prevention.

For DOT purposes RMW is: a waste or reusable material known to contain

or suspected of containing an infectious substance and generated in the diagnosis, treatment, or immunization of human beings or animals, or research related to these activities including the production or testing of biological products.

Proper Shipping Name: REGULATED MEDICAL WASTE UN Identification Number: UN3291

2 general categories of RMW at TTU: Sharps Solid, non-sharps

Any object contaminated with a pathogen or that may become contaminated with a pathogen through handling or during transportation and also capable of cutting or penetrating skin or a packaging material.

Includes needles, syringes, scalpels, broken glass, culture slides, culture dishes, broken capillary tubes, and broken rigid plastic.

Sharps are disposed of in sharps containers. Containers for transport and disposal of sharps must be manufactured for that purpose.

Sharps containers MUST be permanently closed before they are removed from the worksite for submission to disposal contractor.

Solid, non-sharp biowaste include materials:

That have come in contact with humans or animals that have an infectious disease (naturally, or experimentally-induced);

Wastes that have come in contact with infectious materials in the research environment, such as plastic pipettes, gauze, gloves, paper towels, and other items contaminated with potentially infectious materials;

Body fluid/animal fluid sample containers.

Within the lab solid, non-sharp biowaste must be stored in a:

leak-proof container with lid;

the container must be labeled with biohazard symbol;

and lined with a biohazard bag (biohazard symbol is minimum requirement for the waste contractor, MedSafe Waste).

The company MedSafe Waste is the current TTU contractor. MedSafe Waste follows DOT standards. The contractor requirements are:

Non-sharps waste must be in biohazard bags that are securely tied shut.

Sharps must be in permanently closed sharps containers.

All waste must be placed in a closed contractor-provided container for pickup.

Containers must not weigh more than 50 lbs!

No hazardous chemicals or radioactive wastes are allowed in the contract provided containers. Contact EHS for questions about mixed waste.

MedSafe Waste containers are 28

gallon red plastic tubs.

All containers must be lined

with a biohazard bag!

The following must not be mixed in with waste to be disposed of through MedSafe Waste!

Large metal items including prostheses, implants, screws, pins, etc.

Radioactive wastes

RCRA Hazardous Wastes (i.e., hazardous chemicals)

Fetal remains and human cadavers

Compressed gas cylinders/aerosol cans

**Bulk chemotherapy waste

Other: improper packaging, leaky containers, damaged containers, loose sharps, etc.

Use only contractor provided containers- do not use your own containers.

Contractor provided transport containers meet DOT requirements BUT…

Check containers for damage.

▪ Do not use damaged containers! Notify contractor of problem and get a replacement.

Ensure biohazard/symbol is legible.

Biohazardous waste that is collected by MedSafe Waste is treated at a site permitted by the Tennessee Department of Environmental Conservation.

▪ The waste is treated using the TDEC permitted method of shredding the material and then it is chemically treated prior to disposal in a permitted landfill.

1. Line the appropriate container with a biohazard bag. 2. Place waste into the container lined with the bag. 3. Tie the bag closed by twisting. 4. Completely close the container. 5. Leave the waste in a secure, locked area.

Note: A trained person can supervise an untrained person in the packing of regulated medical waste.

The contractor will have the required information preprinted on the paperwork.

Shipping papers serve as both a shipping manifest and a record of final destruction and disposal. These manifests must be retained for 3 years!

Help us help you: send us a copy of your shipping manifests!

Confirmation of destruction is posted online within ~45-60 days.

The records are maintained in database for 3 years.

You cannot allow untrained personnel to sign the waste manifest, as this is an official record of our waste activities.

“…I also certify that the contents of this consignment

are fully and accurately described below by proper shipping name and are classified, packed, marked, and labeled, and in proper condition for carriage by air according to the applicable national governmental regulations.”

waste manifest

Your signature

A 24-hour emergency response phone number is required on the shipping papers for all shipments of hazardous materials.

MedSafe Waste fulfills this requirement.

What do you do in case of a spill of biohazardous materials?

1. Close off the area and notify others. 2. Gather spill supplies:

Fluid-resistant gloves, splash goggles,

Absorbents,

Disinfectant (1:10 household bleach to water, freshly prepared),

Broom, dustpan, other mechanical tools,

Biohazard bag, bucket,

A buddy to help you with the cleanup.

3. Put on Personal Protective Equipment (PPE). Put on gloves and a lab coat.

4. Disinfect the contaminated surfaces (leave surfaces wet with 10% bleach solution for at least 10 minutes).

5. Absorb and remove the spill. 6. Dispose of all wastes as biohazardous waste.

A cut or puncture with a contaminated sharp Entry through broken skin A splash to the eyes, nose or mouth Accidental ingestion

You must: Flush the exposed area for 15 minutes with

running water. Immediately report the incident to your

supervisor.

If potentially infectious materials enter your body through:

BIOHAZARDOUS WASTE STORAGE AREA

Storage area must be secure (locked).

Storage area must be

well-ventilated.

Regulated waste must be

protected from the elements.

Storage areas must be posted

with prominent warning that is

readable from 25 feet.

DOT requires hazmat employers to have a security plan for hazmat shipments that require placarding (signage on the exterior of the vehicle).

Regulated medical waste shipments do not require placarding. Since the shipments do not require placarding, DOT does not require a security plan. However, everyone should be proactive for securing regulated medical waste.

Keep waste storage area locked when an authorized person is not present.

Escort the contractor when they are on site for pickups.

Verify that the name/signature of the contractor on the paperwork matches the ID of the person picking up the wastes.

If you have any questions, contact Environmental Health and Safety

YOU MUST SUCCESSFULLY COMPLETE THE REGULATED MEDICAL WASTE EXAM AND RECEIVE YOUR CERTIFICATE FOR THE TRAINING TO BE COMPLETE. Jim Cobb Director , Environmental Health and Safety jimcobb@tntech.edu Sarah DiFurio Coordinator, Environmental Health and Safety sdifurio@tntech.edu 372-3587