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Regulated Medical Waste Management

Course Number: 498


The human immunodeficiency virus (HIV) epidemic of the mid 1980s raised public concerns about personal health risks resulting from improper management and disposal of medical wastes. In response, the U.S. Environmental Protection Agency (EPA) published “Guide for Infectious Waste Management” in 1986 and Congress enacted the “Medical Waste Tracking Act of 1988,” which required the EPA to develop a program for managing and tracking medical waste.1,2

The EPA created a model program for Managing and Tracking Medical Waste (1989).3 Specifically, it (1) defined medical waste subject to program regulations; (2) established a cradle-to-grave tracking system; (3) required management standards for segregation, packaging, labeling, and storing medical waste; (4) established record keeping requirements; and (5) defined penalties that could be imposed for mismanagement.

The model program regulated medical waste in four states (New York, New Jersey, Connecticut, Rhode Island) and Puerto Rico. From the information gathered, the EPA concluded that: (1) due to the biological instability of most microorganisms commonly regarded as human pathogens, the actual adverse environmental or public health consequences or risks were negligible, (2) the disease-causing potential of medical waste is greatest at the point of generation, and, therefore, (3) medical waste primarily represents an occupational health hazard.

The U.S. Department of Labor Occupational Safety and Health Administration (OSHA) is responsible for safe and healthy working conditions.4 It also operates the job safety and health programs in 29 states. However, 21 states have their own programs, and in 3 states the programs only apply to state and local government employees. The State-by-State Occupational Safety and Health Resource Locator provides program information for specific jurisdictions (Figure 1).5

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Figure 1. State-by-State Occupational Safety and Health Resource Locator.5

The U.S. Centers for Disease Control and Prevention (CDC) and the National Institute for Occupational Safety and Health (NIOSH) have advisory (i.e., non-regulatory) responsibilities related to infection control. The CDC makes recommendations related to the prevention and control of disease. NIOSH conducts research and makes recommendations to prevent worker injury and illness (e.g., selecting, evaluating, and using sharps disposal containers).

The U.S. Food and Drug Administration (FDA) is responsible for setting and enforcing public health regulations to assure the safety and efficacy of medical devices (e.g., sharps containers). The U.S. Department of Transportation (DOT) has regulatory responsibility that affects transporters of regulated waste. The Healthcare Environmental Resource Center (HERC) funded by the EPA’s National Compliance Assistance Centers program provides compliance assistance.6

The purpose of this document is to provide general guidance for the management of regulated medical waste (RMW) in oral healthcare settings. OSHA states that the disposal of RMW must be “in accordance with applicable regulations of the United States, States and Territories, and political subdivisions of States and Territories.”4 The State-by-State Regulated Medical Waste Resource Locator provides program information for specific jurisdictions (Figure 2).7

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Figure 2. State-by-State Regulated Medical Waste Resource Locator.7