Regulated Medical Waste

Self-Inspection Checklist

Guidelines

No Federal regulations cover the disposal of medical waste. However some States such as New Jersey have adopted their own regulations. This checklist is modeled on medical waste regulations issued by the New Jersey Department of Environmental Protection (NJDEP) under the New Jersey Administrative Code 7:26-3A. It applies to the generation, storage, transportation, disposal and management of regulated medical waste. This checklist addresses regulations covering on site generation of regulated medical waste, subsequent temporary storage, and its shipment off site for disposal or treatment. It does not cover regulated medical waste transporters, on site treatment or disposal, or shipment through the U.S. Postal Service and rail shipments. Definitions of terms in bold type are provided at the end of the checklist. Use this checklist as a guideline for handling medical waste. A yes answer to a question indicates that this portion of the inspection complies with the OSHA or U.S. Environmental Protection Agency (EPA) standard, or with a nonregulatory recommendation. Consult the appropriate agency or agencies in your State to determine what regulations are enforced in your State. This checklist should also be used with the Bloodborne Pathogens checklist.

1. If medical waste is generated or stored, has someone determined whether it is a regulated medical waste in your State?
2. If regulated medical waste is generated, is the school registered with your State as a regulated medical waste generator?
3. Is regulated medical waste to be transported off site separated in containers according to the following groups: sharps, fluids (use quantities greater than 20 cubic centimeters as a guideline), and other regulated medical waste?
4. Is regulated medical waste to be transported off site placed in containers that are rigid, leak-resistant, impervious to moisture, strong enough to prevent tearing or bursting under normal conditions of use and handling, and sealed to prevent leakage during transport?
5. Are sharps with residual fluids to be transported off site packaged in puncture-resistant containers?
6. Are fluids (use quantities greater than 20 cubic centimeters as a guideline) to be transported off site packaged in containers that are break-resistant and have tight lids or stoppers?
7. Is regulated medical waste stored in a manner and location that maintains the integrity of the packaging and provides protection from water and wind?
8. Is regulated medical waste stored to prevent rotting or decay, using refrigeration when necessary?
9. Are outdoor regulated medical waste storage areas locked to prevent unauthorized access?
10. Is access to regulated medical waste storage areas limited to authorized persons?
11. Is regulated medical waste stored in a manner that gives protection from animals and does not provide a breeding place or a food source for insects and rodents?
12. Are all non-rigid packaging and inner liners from reusable containers managed as regulated medical waste and not reused?
13. Are reusable containers, used to hold regulated medical waste, decontaminated if the containers show signs of contamination?
14. Are reusable containers used to hold regulated medical waste disposed of as regulated medical waste if the containers can’t be properly decontaminated?
15. Does each package of untreated regulated medical waste to be transported off site display the biohazard symbol or have a water-resistant label or print on the outside of the container with the words medical waste or infectious waste? Note: Red plastic bag(s) used as inner packaging do not need a label.
16. Is each package of regulated medical waste to be transported off site marked on the outside with the following information: the generator’s name and address; the transporter’s name and the State solid waste registration number; the date of shipment; and the identification of contents as medical waste?
17. Is each inner container within a package of regulated medical waste to be transported off site marked with the generator’s name and address?
18. If required by your State, do the transporters of the school’s regulated medical waste have State registration numbers?
19. If required by your State, are State regulated medical waste tracking forms completed for each shipment of regulated medical waste sent off site for treatment, destruction, or disposal?
20. If required by your State, are copies of completed regulated medical waste tracking forms maintained for at least 3 years?
21. If required by your State, are logs maintained of all regulated medical waste that are generated and sent off site for treatment or disposal?
22. If required by your State, are copies of regulated medical waste logs maintained for at least 3 years?
23. If required by your State, are annual generator reports submitted to the appropriate State agency?
24. If required by your State, are copies of the annual generator reports maintained for at least 3 years?
25. If the generator does not receive a copy of the completed tracking form with the handwritten signature of the owner or operator of the destination facility within 35 days of the date the waste was accepted by the initial transporter, are the owner or operator of a destination facility, transporter(s), and intermediate handler(s) contacted to determine the status of any tracked waste (if so required by your State)?
26. If the generator has not received a completed copy of the tracking form signed by the owner or operator of the destination facility within 45 days of the date the waste was accepted by the initial transporter, is an exception report submitted by the generator to the appropriate State agency (if required by your State)?
27. If required by your State, are copies of the exception reports maintained for at least 3 years?

Definitions

Regulated medical waste: in New Jersey) a solid waste, generated in the diagnosis, treatment, or immunization of human beings or animals: cultures and stocks contaminated with infectious agents; pathological wastes; human blood and blood products; sharps such as hypodermic needles, syringes, pipettes, scalpel blades, blood vials, needles with attached tubing, and used slides and cover slips contaminated with blood or other infectious materials; animal waste contaminated with infectious agents; isolation wastes; and unused sharps such as hypodermic needles, suture needles, syringes, and scalpel blades. The following are not considered regulated medical waste: hazardous waste listed in 40 CFR Part 261; household waste generated in households using home self-care; incineration ash generated by burning regulated medical waste; residues from treatment and destruction processes once the regulated medical waste has been treated and destroyed; and human corpses, remains, and anatomical parts that are intended for burial or cremation.