Medical Waste Management: Regulatory Issues and Current Legal Requirements.

As a result of highly publicized incidents involving the presence of medicalĀ  wastes on public beaches and resultant beach closures, public attention recently has focused on the subject of medical waste management. The issues raised, however, extend far beyond purely aesthetic concerns. Medical waste disposal practices further raise serious issues concerning health and environmental risks.

An understanding of these issues often is hampered by a relative scarcity of data. State legislators and federal lawmakers have been actively working on legislation intended to ameliorate the problems posed by medical waste. This paper will examine some of the major issues raised by medical waste management. Attention also will be directed toward legislative efforts in this area.

Defining medical wastes

All wastes generated by health-related facilities are considered medical wastes. Other possible sources include research laboratories, doctors’ offices, clinics, biotechnology firms, nursing homes, veterinary facilities and funeral homes. The wastes created by larger generators certainly should not divert attention from the problems caused by smaller generators.

Judging what actually is “infectious” is most difficult. Vastly differing working definitions of “infectious waste” may result in inconsistent treatment, storage and disposal practices. Inconsistencies, in turn, may affect waste management costs, the choice of treatment technology, and ultimately, the potential health and environmental risks posed by such wastes. An estimated 10 to 15% of hospital waste s are considered “infectious.” However, depending on particular definitions and procedures used, the percentage may vary from 3 to 90.

The Centers for Disease Control, the U.S. Environmental Protection Agency and various state entities have attempted to define infectious waste based on various waste characteristics. The EPA, for instance, defines infectious waste as waste capable of producing an infectious disease. It requires, in addition, consideration of at least four variables associated with disease causation: dose, resistance, portal of entry and presence of a pathogen of sufficient virulence.

In 1987, the CDC published recommendations providing in part that blood and body fluids from all patients be considered potentially infected with human immunodeficiency virus and/or other blood-borne pathogens. But later, in June 1988, the CDC limited the scope of its 1987 recommendations to blood and other body fluids containing visible blood, to semen and vaginal secretions, and to other specific fluids.

The application of EPA, as opposed to CDC, guidelines has major implications for hospitals and other generators of medical waste who are struggling to stay within the law and concomitantly to minimize or eliminate potential health risks. For example, the EPA considers communicable disease wastes to be infectious, but the CDC recommends that communicable disease wastes be managed according to pertinent hospital policy.

Another question concerns whether infectious wastes should, in addition, be classified as “hazardous” and regulated accordingly. The “hazardous” designation might require more costly disposal methods and create problems concerning the siting of hazardous waste facilities. It also might result in more aggressive prosecution of illegal dumpers, lead to the creation of a manifest system for the effective tracking of infectious wastes and better management of such wastes.

Broad categories of waste that should be considered “infectious” are: human blood and blood products; pathological waste; contaminated “sharps” (needles, surgical blades, scissors, etc.); cultures and stocks of infectious agents; isolation wastes; and contaminated animal carcasses and body parts. Other “infectious” materials include: wastes from dialysis units; soiled dressings, sponges, surgical gloves and other wastes from surgery and autopsy; slides, specimen containers, cover slips and other laboratory wastes; and potentially contaminated and infectious equipment used in connection with patient care.

Severity of the problem

The general public has been exposed to incidents involving alleged improper disposal of biomedical wastes because of massive news media coverage. Beaches on the East Coast were closed when medical wastes including sutures, bloody bandages, and vials of blood infected with AIDS — washed ashore. Beaches in Connecticut, Massachusetts, New Jersey, New York and Rhode Island were endangered with hypodermics, gauze dressings, surgical gloves and blood vials Wastes were found on beaches stretching from Maine to Texas, and 200 hypodermic needles found their way to Lake Erie’s shores. The EPA estimates that about 3.2 million tons of medical wastes from hospitals are produced yearly. This figure represents about 2% of the total municipal solid waste stream. Other estimates, though, range from 2.1 to 4.8 million tons annually.

No Responses to “Medical Waste Management: Regulatory Issues and Current Legal Requirements.”

Leave a Reply