Waste Management Plan Development & Implementation
Your practice must develop a medical waste management plan and at least one employee must be designated with the responsibility of implementing it. (An alternate employee should also be selected in case the designated person is unavailable due to illness or vacation, for example.) These employees should have a strong knowledge of the plan to be able to communicate what is expected from your staff to implement the plan components.
Maintaining the necessary documentation is a big part of compliance. You must maintain a copy of your facility’s waste management plan and review/update it annually. The person in charge of recordkeeping should also keep records to show how certain aspects of the plan are being implemented. This also includes shipping papers or manifests, and documents of final destruction. Any permits required for the transport and delivery of your medical waste should be kept on file. Finally, safety data sheets should be updated and all employee training must be documented.
Medical Records Management
The person in charge of your medical records is primarily responsible for managing and maintaining the integrity of both paper and electronic records. To maintain Health Insurance Portability and Accountability Act (HIPAA) compliance, your practice and any company that deals with Protected Health Information (PHI) must ensure that all required security measures are in place. This also includes your business associates (labs, billing services, etc.) and anyone with access to PHI through providing support in those areas (IT support or document destruction services, for example.) Your practice must follow the HIPAA Security Rule and other safeguards, including documenting your office practices and HIPAA training. (See below.)
The person in charge of employee training for your facility should make sure that all employees with occupational exposure receive initial and annual compliance training, including part-time and temporary employees. This training is required by the Occupational Safety and Health Administration (OSHA) and the type depends on the employee’s job roles. The goal is to make sure your entire staff can consistently demonstrate proper handling and management of medical waste. In addition, most organizations conduct HIPAA training annually, as a best practice. Finally, knowledge of US Department of Transportation (D.O.T.) Hazardous Materials Transportation Regulations is recommend due to the liability associated with your medical waste being transported off-site.
The person in charge of safety will ensure that the proper waste disposal procedures and processes are being followed. This includes the collection and segregation of waste, and making sure employees are trained on the proper safety guidelines to follow. Regular inspections, such as checking both medical waste and regular trash receptacles to make sure waste streams are not being mixed, should be conducted. Containers should also be regularly inspected.
It may be that the person in charge of implementing your waste management plan is also in charge of compliance. This person needs a strong knowledge of the plan. They should regularly audit your internal procedures and staff behavior as they relate to managing regulated medical waste, as well as making sure all necessary documentation is up-to-date and on file. As a waste generator, you are required to visit the facility where your regulated medical waste is being treated — this person could also fill that role.
There must be a person designated to sign your waste manifests. This is an important responsibility that should not be taken lightly. Each regulated medical waste load or individual containers within a mixed load will have a manifest including the date of receipt; contact information for your practice (waste generator), the waste transporter, and the waste treatment facility; and a dated signature for each — generator, transporter, and disposal facility. Finally, your waste provider will provide you with a certificate of destruction, after your waste is rendered non-infectious or destroyed and disposed. Your practice has “cradle-to-grave liability” and it is your responsibility to ensure that your medical waste has been handled in a way to protect both human health and the environment.
All employees with job responsibilities that involve any aspect of medical waste generation or management should be familiar with your waste management plan, whether they fulfill any of the specific roles above or not. We realize that, in smaller offices, one person may be responsible for all of the functions that we have outlined. However, by clearly detailing what is involved for each function, we’ve hopefully made the process more streamlined and manageable.