Managing medical waste is not for the faint of heart . . . and neither is managing a medical office. Your facility’s staff must adhere to strict, sometimes time-consuming medical waste guidelines and regulations while providing the highest level of patient care. You must protect the health of your patients, your employees, and on a larger scale, the community-at-large and the environment. Following best practices in health care delivery, medical waste management, and medical office management can streamline processes and help ensure the best delivery of service in each area.
However, no matter how well your staff follows processes and procedures, mistakes will be made. Handling medical waste can be confusing and your medical office is a fast-paced environment. To help, we’ve compiled a list of common medical office mistakes related to compliance for you to keep as a handy reference. Perhaps sharing these with your staff can jumpstart some helpful conversations related to compliance issues.
1. Not Training Everyone in the Office
Compliance training. It’s sometimes difficult to determine who needs what training. According to Department of Transportation (DOT) regulations, unless you have a pharmacy on site, only your compliance point-person and the manifest signer (these may be the same person) need to complete annual DOT compliance training. However, not following DOT regulations with regard to tying bags is a mistake that is often seen.
Note: The inner bag must be tied in a “twist and loop,” or what we call “goose neck” style, tie prior to transportation to prevent spill or leakage in the event of container roll over. As the waste generator, you can be fined for each violation that is found.
There are some areas where all employees should be trained. For example, if your medical facility uses equipment or material that emits any radiation, your entire staff should take training to protect against those risks. Even interns and part-time employees should receive training. All employees should also be trained in HIPAA compliance. A recent fine levied against MD Anderson Hospital came as a result of an intern losing a zip drive that contained patient information. Did the intern not receive HIPAA compliance training and if she had, would it have made a difference? When in doubt, train everyone.
2. Disposing Solid Waste as Regulated Medical Waste
Unfortunately, waste services providers often come across non-conforming waste or waste that has not been properly segregated. Your staff must properly categorize and segregate medical waste in order to maintain compliance. There are many mistakes that can be made classifying medical waste. One of the most common mistakes is to needlessly dispose regular solid waste as regulated medical waste (RMW). Solid waste should only be disposed of as RMW if it came into contact with contaminated materials. Besides being an issue of mismanagement, it can be a costly mistake for your medical facility, since it is more expensive to dispose of RMW than main stream trash, which should never be placed in medical waste bins.
3. Container and Storage Issues
We’ve probably all been guilty, at one time or another, of putting too much trash into a container. We use our foot to compress the contents and if we’re lucky enough for the trashbag not to burst, we succeed in piling in more trash. Why is this not acceptable with medical waste?
Besides the fact that medical waste should be handled as little as possible, container lids must be able to fit securely and overcrowding the container prevents this.
Using Damaged Containers
It’s much easier to use what is already in place instead of replacing an existing container. The existing one may have a leak, but since it’s small, there’s nothing to worry about, right? Wrong. If a container leaks, you must place it in another, separate container. Using leaky or damaged containers is a violation of medical waste guidelines and could result in a fine. Designating someone to routinely check your containers can help you make sure they are not damaged.
Following proper storage procedures is another part of managing medical waste. For example, pathological waste must be in the appropriate container(s) and in refrigerated area. All medical waste must be stored in a secure area that is not accessible to the general public, which is not the case in many facilities. Also, there is not supposed to be anything else in the storage area; which again, is not always the case. All storage areas must be properly labeled with the words “biohazardous,” “infectious,” and/or the international biological hazard symbol. The Alabama Department of Environmental Management (ADEM) provides the complete guidelines for storage of untreated medical waste.
These are a few of the more common mistakes medical offices make. We want to be a resource for our customers and provide the education and training that you need to effectively maintain compliance.