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Understanding Regulated Medical Waste
by Capaccio Environmental Engineering, Inc.

Regulated medical waste is defined by the U.S. Department of Transportation (DOT) as a hazardous material.  The DOT requires detailed training and certification for anyone shipping hazardous materials.  Anyone who is involved in the transport of regulated medical waste must have general awareness, function-specific, and security training.  This requirement also includes any employee who performs pre-transportation functions for the shipment of medical waste, such as packaging, marking, and completion of shipping papers.  Employees must be trained to correctly classify, package, and mark biohazardous waste, as well as complete any documentation required.

Regulated medical waste is classified under hazard class 6.2 of the DOT Hazardous Materials Regulations because it poses a risk of disease transmission to humans or animals.  The definition for Regulated Medical Waste can be found at 49 CFR 173.143(a)(5). 

The DOT defines regulated medical waste as:
A waste or reusable material, other than a culture or stock of an infectious substance, that contains an infectious substance and is generated in:

  1. The diagnosis, treatment or immunization of human beings or animals,

  2. Research pertaining to the diagnosis, treatment or immunization of human beings or animals, or

  3. The production or testing of biological products

Discarded cultures and stocks of infectious substances are classified under hazard class 6.2 and called infectious substances.  Discarded cultures and stocks must meet more stringent packaging requirements than regulated medical waste.

In Massachusetts, facilities must also comply with the MA Department of Public Health (MA DPH) regulation 105 CMR 480.000, Minimum Requirements for the Management of Medical or Biological Waste.  All medical or biological waste must be treated on-site or sent off-site for treatment at least once per calendar year.  Annual bloodborne pathogens training, in accordance with OSHA 29 CFR 1910.1030, is required for all personnel who may potentially handle medical or biological waste.

The requirements for packaging Regulated Medical Waste are located in 49 CFR 173.197.  In 2004, the DOT pre-empted the MA DPH requirement in the previous version of 105 CMR 480.000 that 3 mil biohazard bags must be used for solid waste that is transported off-site.  The DOT requirement is that plastic bags contain sufficient absorbent material to absorb all liquid during transportation.  Also, the bag must be capable of being held in an inverted position for a period of five minutes without leakage.

Need Assistance?
For further information, please contact Colleen Walsh at Capaccio Environmental Engineering, Inc. at 508.970.0033 x129 or by email at cwalsh@capaccio.com.

 

 

 

 

 

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