Waste Management for the Physician Office

By Terry Jo Gile, MA Ed. MT(ASCP)

The Safety Lady®

Physician office waste streams are often taken for granted or overlooked entirely.  What once was a simple way to dispose of blood and body fluids and the equipment and supplies that came into contact with them, has now been replaced with a sophisticated mechanism for the disposal of various waste streams within the office setting. 

Categories of waste include chemical, infectious, radioactive, controlled substances and pharmaceutical, multihazardous, sharps and nonhazardous waste.  Each has its own characteristics and requirements for removal.   Waste can be governed by the Environmental Protection Agency (EPA), the Occupational Safety and Health Administration (OSHA), the Resource Conservation and Recovery Act (RCRA), the Department of Transportation (DOT), the Nuclear Regulatory Commission (NRC), the Drug Enforcement Agency (DEA) as well as state and local agencies.  It is prudent to contact your municipality for its requirements.

The first step in developing a waste management program is to perform an audit of the facility.  The checklist below will help guide you.

Waste Management Program Audit     

Completed                                                                                                            YES       NO                DATE

1.

Are the scope, goals, and objectives of the waste management program clearly defined?

 

 

 

2.

Must the facility’s EPA classification as a hazardous waste generator be revised?

 

 

 

3.

Has the local sanitary sewerage code been reviewed recently for applicability?

 

 

 

4.

Is the disposal of chemicals and biological substances in compliance with the local sanitary sewerage code?

 

 

 

5.

Has an annual survey of the hazardous chemicals used in the physician’s office been completed?  For each chemical:

 

 

 

 

·        Is the chemical specifically listed within current EPA code?

 

 

 

 

·        If not, does the discarded chemical have the general characteristics of a hazardous waste (i.e. is it ignitable, corrosive, reactive, or highly toxic)?

 

 

 

6.

Does the office’s procedure manual and/or written chemical hygiene plan specify the method to be used for disposal of each hazardous chemical?

 

 

 

7.

Are all the infectious wastes that require decontamination properly treated before being discarded?

 

 

 

8.

Are all sharps properly segregated and discarded in puncture-resistant containers?

 

 

 

9.

Does the method for disposal of all radioactive waste comply with NRC regulations?

 

 

 

10.

Are hazardous wastes consistently segregated from nonhazardous wastes at the point of generation?

 

 

 

11.

Is the office’s hazardous waste safely packaged for transport?

·        Are appropriate warning label placards applied consistently to the exterior of the packaging?

 

 

 

12.

Are wastes properly stored before being discarded? 

·        Is the area sanitary and uncluttered? 

·        Are appropriate warning signs and emergency procedures posted? 

·        Are the waste handling records up to date and readily retrievable?  (This includes records of waste inventories with accumulation dates, shipping, manifests, inspection records, and results of the waste analysis.)

 

 

 

13.

Is there an active program for hazardous waste minimization?

 

 

 

14.

Have the offices’ contracts with carriers of hazardous waste been recently reviewed for evidence that the carrier has obtained the required permits from all relevant authorities?

 

 

 

15.

Has each disposal facility provided the physician office with a complete description of all disposal processes?

 

 

 

16.

Is there a training program for all employees who generate or handle hazardous waste?

 

 

 

 
  • Is it provided for new employees, as well as in-services for current employees?

 

 

 

 
  • Does it include the proper use of personal protective equipment and the details of safe work practices?

 

 

 

 
  • For employees who use a chemical that meets the requirement of OSA’s Hazard Communication Standard and OSHA’s Rule on Hazardous Substances in Laboratories, does the program specify the location of all written materials, including the location of the Material Safety Data Sheets and other pertinent references, as well as how employees may access them?

 

 

 

17.

Have appropriate contingency plans for spills and other accidents been drawn up and implemented?

 

 

 

 

Once the audit has been performed, all applicable waste streams must be identified and plans made for appropriate removal.  Waste streams associated with the physician office can include:

·       Sharps

·       Infectious waste

·       Chemical waste

·       Controlled substances or other pharmaceuticals

·       Radioactive substances

·       Regular trash

·       Recycled waste

Sharps include scalpels, broken glass, needles, etc. and must be placed in a rigid sharps container.  Once the container is ¾ full, it must be closed and disposed of according to local requirements.  Infectious waste includes anything contaminated with blood or body fluids that are dripping including dressings and exam rooms pads.  Chemical waste includes any alcohols, acids, flammables, pesticides and caustic materials that might be used in a physician office exam room, nurses’ station, and laboratory or for housekeeping purposes.  Controlled substances include chemotherapy as well as narcotics.  Radioactive substances include implanted devices used for treatment.  Recycled waste includes paper, glass, aluminum cans and foil and plastics.

Waste should be examined to determine if it includes any hazardous waste.  Such waste must be disposed of according to EPA guidelines.  Waste streams should never been mixed (e.g.: regular trash mixed in with infectious red bag waste) as it must be disposed of according to the more strict of the two (e.g.: as infectious waste).  This can get very costly in a short period of time.   A recycling program that meets with local codes should be instituted and appropriate containers available for use.  A key practice for managing waste is to promptly remove it from the facility.  This is part of good housekeeping and demonstrates an active, sound institutional waste management program to patients and employees.

The ideal plan is one that meets regulatory requirements reduces liability, is cost effective and workable within the facility.  The goals and objectives of the waste management program must be defined and protect the health of the employees and patients as well as the environment. 

For good infection control, weekly pickup of waste should be done at a minimum.  Before contracting for services, obtain proposals from at least three different vendors if possible.  The following are guidelines for selecting a firm for waste removal:

·       Identify your hazardous waste streams and approximate volumes

·       Contact both large and small waste management firms to meet and discuss your specific waste streams and how they would be handled to final disposal and request a proposal

·       Conduct a site visit for each of the finalists and require an audit packet which includes permits detailing what each firm can legally accept as well as insurance, liability coverage and references.

You can call the DOT Hotline for information on transportation regulations at 1-202-426-2075.  

Of course the best thing you can do for the health of your employees as well as your patients is to minimize the amount of waste generated.  In today’s disposable world, “going green” is considered exemplary.  Here are some ideas:

·       Source Separation

o   Use multiple waste collection containers to keep waste types separate, so that each waste type can be optimally managed

o   In offices, use separate receptacles for recyclable paper

·       Waste Segregation

o   Keep waste type segregated during collection, storage, transport, treatment and disposal

o   Keep needle boxes out of red bags

·       Source Reduction

o   Keep purchases in small, manageable quantities

o   Use nonhazardous or less hazardous materials whenever possible

·       Recycling

o   Recycle, aluminum cans, paper, plastic, glass and other solid waste items

o   Recycle solvents where appropriate

·       Process changes

o   Substitute nonhazardous cleaners from caustic ones

o   Substitute ozone-friendly spray disinfectants

·       Hazard reduction

o   A treatment or procedure that reduces the hazard of the waste, making it easier or less expensive for disposal

o   Neutralize waste acids so they can be disposed of in the sanitary sewer

Additional help in establishing your waste management plan can be found in the Clinical Laboratory Standards Institute (CLSI) document GP05-A2 (GP05-A3 will be released sometime in 2010).  This is a comprehensive 86 page document outlining the steps to be taken that would be helpful as a reference tool not only in the clinical laboratory but for a physician office practice as well.