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Risky Business

How you handle, store and dispose of medical waste is strictly regulated, so make sure to do your homework.

Risky Business
OSHA standards outline many of the protocols for handling hazardous waste.

Processing medical waste can be an overwhelming responsibility within a veterinary practice. Team members should be aware of and follow specific guidelines when dealing with infectious waste, biohazardous waste, and anatomical or pathological waste. Questions we often face and must know the answers to include “What constitutes hazardous waste?” and “How do we handle, store and dispose of it?”

Fortunately, resources and guidelines are available. What’s important to understand is that state guidelines often are more rigorous than federal regulations regarding medical waste management, segregation and disposal. Still, veterinary practices must follow the policies of the U.S. Environmental Protection Agency, the Occupational Safety and Health Administration, the Drug Enforcement Administration, the Centers for Disease Control and Prevention, and even the Department of Transportation.

Defining Hazardous Waste

Biohazardous veterinary waste is divided into these subcategories:

  • Pathology waste includes animal parts, tissues, fluids and carcasses suspected by the attending veterinarian of presenting a zoonotic risk to employees.
  • Laboratory waste includes specimens or cultures that contain pathogens known or suspected of being highly communicable to humans. It includes vaccines, such as those for contagious ecthyma and brucellosis, that pose a human health risk.
  • Pharmaceutical waste includes discarded noncontrolled pharmaceuticals and chemotherapy waste. Controlled drugs require the use of a reverse distributor, as mandated by the DEA.
  • Sharps waste includes any device with acute rigid corners, edges or protrusions capable of cutting or piercing. The category includes but is not limited to needles, catheter stylets, surgery blades, and broken glass items such as slides, coverslips, mercury thermometers and pipettes.

Fluid or dried blood, feces, urine, excretions, sputum, secretions, surgery drapes, soiled sanitary pads, gauze pads and surgery supplies not contaminated with pathogens known or suspected by a veterinarian of being highly communicable to people do not constitute medical waste. Noncontagious animal parts, fluids and excretions are not biohazardous and do not need to be placed in medical waste receptacles. These items can go into the practice’s trash bin.

Use caution, however, if a trash receptacle kept outside the building is not secure. I suggest that you dispose of identifiable animal parts the same way you handle deceased animals, whether by cremation or rendering.

Many veterinary practices are small quantity generators, meaning they generate less than 200 pounds of medical waste a month. Small quantity generators must register with local health authorities, provided the jurisdiction has a medical waste management program.

Handling Hazardous Waste

OSHA standards outline many of the protocols for handling hazardous waste. Make sure to identify and address the hazards within your practice and develop safety plans for each.

Personal protective equipment is essential when anything hazardous is handled. Provide the PPE needed to protect your team, and conduct appropriate training. The ultimate goal is to protect employees from injury or illness related to known hazards.

Storing Hazardous Waste

Approved sharps containers are a must in clinics. Make sure to place them in all areas where sharps waste is generated. Receptacles come in many sizes, so choose one or more based on your sharps volume and available space.

Here are additional tips:

  • Sharps containers must be resistant to punctures, leaks and tampering, properly labeled, kept upright and never overfilled.
  • When full, the containers must be closed securely and sealed.
  • Your state might regulate how long you can store full sharps containers.
  • Dispose of sharps properly through your waste disposal provider, whether a mail-back service or hauler.

Hazardous waste receptacles are required for all other regulated waste and must be large enough to accommodate the volume. How the containers are stored before pickup is regulated because of the risk to employees, the general public and the environment. Storage areas must be secure and inaccessible to the public.

Depending on the amount and types of medical or hazardous waste and the length of storage, a refrigerator or freezer might be required.

You are not required to accept sharps or pharmaceutical waste from clients, but you can. If you do, you are responsible for the proper disposal. Practices that do not accept home-generated waste should direct clients to community takeback locations.

Disposing of Hazardous Waste

A cradle-to-grave process for dealing with hazardous waste is essential. How you dispose of the waste depends on the type and quantity.

Most practices contract with a waste disposal company that picks up receptacles on a schedule tied to the type and volume of waste. State-specific regulations come into play.

On-site destruction can use specially designed equipment that renders medical waste harmless and ready to go in the trash. This option might be good if you generate small amounts.

Lastly but certainly not least, one of the most important things to know about veterinary waste disposal is that your responsibility does not end when the waste leaves your clinic. You could be liable for any harm caused from the moment the waste is generated until it is treated, destroyed or delivered to an approved disposal site. The takeaway: Carefully choose your waste services provider. Ensure that the company is licensed to handle what you produce, has all necessary transportation permits, complies with state and federal requirements, and provides a manifest at pickup and a certificate of destruction.

Don’t be pressured into signing a long-term contract with a disposal company pushing a level of service more than what you need or services equivalent to what a human medical facility would want. Read all service agreements carefully, and be mindful of the date of an automatic contract renewal.

Getting Technical columnist Sandy Walsh is a veterinary practice management consultant, speaker and adviser. She is an instructor for Patterson Veterinary Management University and continues to work in a small animal practice. She has over 35 years of experience in the veterinary field and brings her in-the-trenches experience directly to readers.