Hiring a medical waste service provider doesn’t mean you can surrender responsibility for how your waste is handled. Your medical facility is responsible for its medical waste from the moment it’s generated until the moment it’s rendered harmless and can be recycled or thrown away. Any incident with your medical waste is your organization’s responsibility, even when you’ve contracted with a fully permitted waste service provider. They can make mistakes that result in penalties and fines for your practice.
We’ve compiled a list of a few common things that your waste management provider might miss if they’re not diligent.
Discovering missing permits is one of the easiest ways to prevent possible infractions and reduce the risk of penalties and fines.
Regulated Waste Transportation Permits
Your medical waste services partner should maintain all mandatory permits for transporting regulated medical waste. These include state permits for medical waste transportation and hazardous waste transportation. To transport medical waste in any motor vehicle, your partner needs the appropriate permit from the Department of Transportation (DOT).
Note: If they do not have this permit, merely driving away from your facility with waste would be grounds for an immediate citation for both the waste provider and your medical office.
Your waste partner should also maintain a state notification of regulated waste, properly filed with the Environmental Protection Agency (EPA). This notifies the regulating agency that they engage in the transportation and management of regulated waste categories.
Finally, to transport pharmaceutical waste, your partner must have a valid pharmaceutical waste permit from the Alabama State Board of Pharmacy. This permit can be easily overlooked and is one of the most frequently forgotten waste permits.
Regulated Waste Disposal Permits
Many waste transportation companies don’t treat the waste themselves. That means that you must verify who their treatment facility is and make sure they have the appropriate permit to protect your liability. A company that doesn’t treat your waste may also neglect to tell you that you are required to visit and inspect any treatment facility where your medical waste is treated. A company that does treat and transport your waste is required to have a specific permit for that activity.
Missing or “Mis-creating” a Change in Generator Status
Regulations and reporting requirements for medical waste are structured based on the amount of hazardous waste that is generated. Your waste services provider should be knowledgeable about all state and federal regulations, including generator classification, and be trained to adhere to them.
A hospital group in South Carolina unknowingly violated EPA and state regulations regarding storage and identification of hazardous waste when its service provider improperly labeled many non-hazardous wastes as hazardous. The improper labeling resulted in the hospital, which had been classified as a low producer of hazardous waste, being reclassified as a greater producer. Fines were levied against the hospital for not meeting the regulations and reporting requirements for larger generators.
Missing Container or Labeling Mistakes
Safe containment and proper labeling is a key part of medical waste compliance. Properly preparing medical waste for pickup and transportation is your responsibility — including packaging and labeling. However, you should be confident in your waste services partner’s ability to catch any mistakes that you or your staff might make. Even if you have designated someone to routinely check your containers, a damaged container could still go undetected. Incorrect labeling could occur; for example, not including the universal hazardous symbol.
Instead of contracting with a provider who is only interested in rushing from one pickup to another to finish their job as quickly as possible, choose to work with a provider whose employees take the time to quickly and accurately inspect the containers and labels. Their goal shouldn’t just be transporting your waste, but doing it in the most efficient and correct way possible to protect your practice.
The entire waste disposal process must be documented to maintain compliance, and this is where the waste manifest form comes into play. The EPA’s hazardous waste manifest system is designed to track waste from the time it leaves your facility until it reaches the off-site waste management facility that will store, treat, or dispose of the hazardous waste. Each dedicated regulated medical waste load or individual containers within a mixed load should have a manifest that includes the date of receipt, the name/address/phone number of the waste generator/waste transporter/waste treatment facility, and the dated signature of each (generator/transporter/disposal facility). You should also receive a certificate of destruction after your waste is treated.
Some companies give a certificate of destruction at the time they pick up your waste, which is not proper since your waste is not treated at that point. Missing or inaccurate documentation and failure to maintain a record of each waste shipment collection and deposition can result in hefty fines for you, the waste generator.
Diligence on your part in selecting the right partner for your medical waste disposal needs, correctly training your employees, and maintaining compliance can help you make sure that nothing is missed in the waste handling process.