For the administrator or office manager who is in charge of keeping all the medical waste management ducks in a row for her employer’s clinic or practice, keeping on top of employee medical waste compliance training is essential to that process. After all, failing to meet training requirements can have consequences. Poor training can endanger employees and the environment, and it can cost your employer dearly should a lapse in training standards result in citations and fines. So what do you need to know to ensure that everyone gets all the training they must have to keep your employer in line with federal and state requirements?
What OSHA Requires
The Occupational Safety and Health Administration (OSHA) has a number of training requirements that apply to employees involved in the handling of medical waste. These include:
Bloodborne Pathogens (BBP) training – OSHA’s Bloodborne Pathogens Standard requires that any employees that may be exposed to blood or other potentially infectious materials undergo BBP training. New hires must undergo BBP training within 10 days of being hired, and existing employees must undergo this training every year.
Hazardous Communication and Chemical Safety (HAZCOM) training – OSHA requires that any employee who may be exposed to harmful chemicals or other hazardous materials receive training in the hazards these substances create and the safety measures they must take to mitigate those hazards.
Personal Protective Equipment (PPE) – OSHA requires all employees who have the potential to be exposed to hazardous chemicals or infectious materials be provided with PPE training. This training instructs workers on the types of PPE they should use and proper methods of using it to protect against direct and secondary contamination.
Waste Handling and Classification Regulations – This OSHA course is necessary for your employer’s compliance point-person as well as any employees who may be exposed to regulated medical waste. It offers instruction in federal and state guidelines for developing safe and compliant medical waste handling procedures, including training on waste preparation, packaging and labeling.
What D.O.T Requires
D.O.T. Hazardous Materials Transportation Regulations – This training is important to ensuring medical waste compliance for your clinic or practice. While your medical waste service provider is largely responsible for complying with these regulations, your employer is still liable for medical waste after it is picked up by that provider. Offering this training course for employees who oversee medical waste handling or sign manifests for medical waste pick-ups can help ensure that these workers know what to look for in evaluating your service provider’s compliance with D.O.T. regulations.
What EPA Requires
Pharmaceutical Waste Identification, Segregation and Disposal – This training should be provided to workers who sign manifests for hazardous waste pick-ups or any employees who handle drugs or other pharmaceuticals. It educates these workers in the requirements of the EPA’s Resource Conservation and Recovery Act (RCRA) for the handing and disposal of pharmaceutical waste.
What HIPAA Requires
Health Insurance Portability and Accountability Act (HIPAA) – HIPAA regulations, of course, are all about proper handling of protected health information (PHI). So just how does that relate to medical waste compliance? It is relevant to waste handling because certain items that turn up in medical waste streams may include PHI, such as IV bags, specimen cups or blood collection vials, and any employee who comes into contact with PHI is required to have HIPAA training.
What ADEM Requires
ADEM stands for the Alabama Department of Environmental Management, which is the state agency that regulates Alabama’s medical waste. As a medical waste producer, your employer is responsible for providing ADEM with a written waste management plan that details your organization’s policies and procedures for medical waste management. Among the requirements for that plan is training on proper waste collection, handling and transportation techniques to minimize risk to employees who come into contact with medical waste.
What TDEC Requires
TDEC, which stands for the Tennessee Department of Environment & Conservation, regulates medical waste in that state. If your employer is a medical waste producer in Tennessee, TDEC requires that all employees who handle sharps have BBP training and that any worker that package or sign shipping manifests for medical waste have DOT hazardous materials training.
Other employee training courses that may be beneficial to ensuring medical waste compliance under some circumstances include OSHA’s Fire Prevention and Fire Extinguisher Types training and Radiation Orientation courses. Lastly, it is important to make sure that any training provided to your employees is thoroughly documented to ensure that your employer is covered should the need to prove compliance with state and federal regulations arise.