Transporting regulated waste products is an essential function of any medical facility, but how do you know if it’s being managed correctly?
It can be tempting to assume that once you’ve found a medical waste provider your job is done, but based on state and federal regulations and guidelines, that is not the case. Your medical facility is responsible for its medical waste from the moment it’s generated to the moment it’s properly disposed of or destroyed. So, how do you avoid penalties and fines when working with a waste management provider?
Here is some important information to remember when you’re looking for a medical waste provider, along with a complete list of required permits to check even after you’ve signed the contract.
"Cradle-to-Grave" Medical Waste Requirements
The “cradle-to-grave” guideline for managing waste means your medical facility is liable for its regulated waste from its “conception,” when created in your facilities, to its “end,” when it is 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.
For this reason, it’s important to treat your medical waste provider as an extension of your operations, especially when it comes to verifying their compliance with all relevant legal and regulatory requirements.
Regulated Waste Disposal Permits
One simple, yet pertinent, task to perform when evaluating any medical waste service partner is to do a full review of their permits. Discovering missing permits is often a good indicator that the medical waste provider is cutting corners in other areas such as improper handling, manifesting, transporting and treatment of your regulated medical waste..
To comply with legal requirements and protect your facility from liability, your chosen waste management partner should maintain these mandatory permits, when relevant:
State Medical Waste Transportation Permit
Your waste management provider should have a medical waste transportation permit from the Alabama Department of Environmental Management (ADEM). This permit is the baseline which allows a provider to transport medical waste of any type or in any capacity.
State Hazardous Waste Transportation Permit
Your waste partner should also maintain a hazardous waste transportation permit from ADEM. This covers any hazardous waste, including hazardous pharmaceuticals in many cases.
Department of Transportation Permit
To transport medical waste in any motor vehicle, your partner needs to have the appropriate permit from the Department of Transportation (DOT). If they do not, merely driving away from your facility with waste would be grounds for an immediate citation for both the waste provider and your medical facilityoffice.
Notification of Regulated Waste Activity
Your chosen partner must maintain a state notification of regulated waste, properly filed with the Environmental Protection Agency (EPA) to notify regulating authorities that they engage in the transportation and management of regulated waste categories.
Pharmaceutical Waste Permit
In order to transport pharmaceutical waste, your partner needs to have a valid pharmaceutical waste transportation permit from the Alabama State Board of Pharmacy. This permit is required to transport pharmaceuticals of any kind.It is one of the most frequently forgotten permits for waste management providers which could lead to a violation for your medical facility.
Medical Waste Treatment Permit
Any waste provider that treats medical waste is required to have a specific permit for that activity. Since many waste transportation companies don’t actually treat the waste themselves, you must verify who their treatment facility is and ensure they have the appropriate permit to protect your liability. You are required to visit and inspect any treatment facility where your medical waste is being treated.
Ultimately, discovering missing permits is one of the easiest ways to prevent possible infractions caused by medical waste compliance. By verifying that your chosen medical waste provider has maintained all relevant permits you will reduce the chances of penalties and fines. In addition carefully reviewing the custody and disposal chain for all of your office’s waste—from the “cradle to the grave”—limits your medical facility’s liability and ensures productive operations.
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