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HANDLING, PACKAGING & TRANSPORT OF WASTE
Specific procedures for handling, packaging and transporting medical waste must be observed to ensure that healthcare workers, waste handlers, and the general public are not exposed to infectious materials while such waste is being collected, transported and treated before final disposal. Both federal and state regulatory agencies have jurisdiction over various aspects of medical waste packaging, handling and transport.
FEDERAL REGULATIONS
The Occupational Safety and Health Administration (OSHA), in its Bloodborne Pathogen standard (29 CFR §1910.1030) imposes the following requirements for Regulated Waste containment and packaging at the point of generation:
Contaminated Sharps shall be held and transported in containers that are:
Þ closable (and closed prior to transport)
Þ puncture resistant
Þ leak-proof on the sides and bottom
Þ labeled or color coded to indicate BIOHAZARD, in conformance with the standard
Þ maintained upright throughout use and transport
Þ placed in a closable, secondary container, designed to prevent leakage during handling and transport and labeled or color coded to indicate BIOHAZARD in conformance with the standard, if leakage from the primary container is possible
Other Regulated Waste shall be held and transported in containers that are:
Þ closable (and closed prior to transport)
Þ constructed to contain all contents and prevent leakage during storage and transport
Þ labeled or color coded to indicate BIOHAZARD, in conformance with the standard
Þ placed in a closable, secondary container, designed to prevent leakage during handling and transport and labeled or color coded to indicate BIOHAZARD in conformance with the standard, if contamination of the outside of the primary container has occurred or is possible
The United States Department of Transportation (USDOT), through its hazardous materials (HAZMAT) regulations (HMR; 49 CFR Parts 171-180), governs the transportation of potentially infectious materials. These materials are classified as Division 6.2 materials, which include Infectious Substances, Diagnostic Specimens, Biological Products and Special Medical Waste. As with other HAZMATs, there are specific packaging requirements for Division 6.2 materials. However, unlike other HAZMAT carriers, private transporters of Division 6.2 materials are not required to register with the USDOT or to placard their vehicles.
USDOT divides infectious waste materials subject to transport regulations into two general categories:
(1) Special Medical Waste (RMW), and (2) Discarded Cultures and Stocks of Infectious Substances. Both are considered HAZMATs, but USDOT believes that Discarded Cultures and Stocks of Infectious Substances present a greater risk during transport. Hence, the packaging performance requirements for these materials are greater.
Special Medical Waste (RMW)- When Diagnostic Specimens and Biological Products are handled as part of a waste stream, they are considered to be RMW. RMW offered for transport and treatment must be packaged in accordance with DOT’s General Packaging Standards as described in USDOT; 49 CFR §173.24, §173.24a. and §173.197. This standard directs that each package used for the shipment of RMW must be designed, constructed, maintained, filled and closed, so that under conditions normally incident to transportation, there will be no identifiable release of bio-hazardous materials to the environment. Prior to being placed in a container, the material must be placed in a three (3) mil or equivalent plastic liner that is no more than 175 liters (46 gallons) and may weigh no more than 22 lbs. The liner must then be twisted and tied with a minimum of entrapped air. The bag must be capable of being inverted for five (5) minutes without leakage.
Containers must be closable, rigid, puncture resistant, leakproof on the sides and bottom, labeled with the universal BIOHAZARD symbol, and able to meet the following performance test criteria:
Þ withstand repeated free-fall drops from 30 feet, without leakage from the primary (inner) receptacle
Þ withstand these drop tests after 5 minutes of water immersion and then no more than 30 minutes draining
Þ withstand these drop tests after being held for 24 hours at 0°F
Þ withstand 3 foot drops onto a steel rod, without leakage from the primary (inner) receptacle
Discarded Cultures and Stocks of Infectious Substances - Cultures and Stocks ofInfectious Substances must be packaged in accordance with USDOT’s Performance-Oriented Packaging Standard in 49 CFR §173.196, which requires an inner package comprising a watertight primary receptacle; a watertight secondary packaging; and an absorbent material, sufficient to absorb the entire contents of the primary receptacle, that is placed between the primary receptacle and the secondary packaging. In addition, for transportation, these materials must be contained in an outer packaging capable of meeting the performance test standards of 49 CFR § 178.609, which includes the 30-foot drop tests under various conditions and a penetration test.
In general, USDOT does not authorize bulk transport of Discarded Cultures and Stocks of Infectious Substances. Bulk packaging is defined as a package that has a maximum internal capacity greater than 119 gallons (450 liters). The Baltimore Regional Medical Waste Waste-to-energy uses 211-gallon reusable carts to transport RMW. In addition, these carts meet the test criteria of the USDOT’s Performance-Oriented Packaging Standard. This enables transport of both RMW and Discarded Cultures and Stocks of Infectious Substances
types of waste, as long as the primary (inner) container used by the Generator meets DOT performance requirements.
USDOT requires that all shipments of Special Medical Waste or Discarded Cultures and Stocks of Infectious Substances be accompanied by appropriate shipping papers. These shipping papers must fully describe the waste, including:
Proper Shipping Name
Hazard Class
Identification Number
Packing Group
Quantity
This information must be shown in sequence with no additional information interspersed. For example:
“Special Medical Waste, 6.2, UN3291, PGII, 150 lbs.”
or
“Infectious Substance, 6.2, UN2814, PG not assigned, 25 lbs.”
The Special Medical Waste shipping paper provided by Curtis Bay Energy is called SPECIAL MEDICAL WASTE TRACKING FORM, and includes the following information:
Þ Tracking Form Document Number
Þ Generator name, identification number, address and telephone number
Þ Name and Maryland identification number, hauler number, and vehicle number for each transporter
Þ Name, address and telephone number of the primary Designated Facility and alternate Designated Facility
Þ Description of the waste
Þ Total quantity of waste by units of weight or volume, and type and number of containers
Þ Generator’s certification: “I hereby declare that the contents of this consignment are fully and accurately described above and are classified, packed, and labeled, and are in all respects in proper condition for transport by highway according to applicable international and national government regulations, and Maryland Statutes and Regulations.”
Þ Date and handwritten signature (not initials) of the Generator’s representative
Þ Date of acceptance and handwritten signature(s) (not initials) of the transporter representative(s)
Þ Explanation of any information discrepancies on the manifest
Þ Date of acceptance and handwritten signature (not initials) of Designated Facility representative
The SPECIAL MEDICAL WASTE TRACKING FORM is a four-part form. The dispensation of each copy is:
CANARY - GENERATOR RETAINS (when transporter receives shipment)
PINK - TRANSPORTER (retains for their records)
GREEN - FACILITY (retained by Designated Facility)
WHITE - FACILITY MAILS TO GENERATOR (returned to Generator with invoice for service)
STATE OF MARYLAND REGULATIONS
PACKAGING - Generators of Special Medical Waste must ensure that when waste is offered for transport and/or treatment, it is packaged and labeled in accordance with the following requirements:
Þ All Blood or Blood-soiled Articles shall be placed in a container that will prevent Blood from spilling or otherwise leaving the container.
Þ All Anatomical Materials shall be placed in leakproof bag(s) with a combined thickness of at least 3 mils or equivalent strength, and the bag(s) shall be placed in clearly labeled rigid containers to protect the bag(s) from puncture.
Þ All Sharps shall be placed in combustible, impervious, and puncture proof containers.
Þ All other infectious or potentially infectious waste materials, including Anatomical Material, Contaminated Material, Microbiological Laboratory Waste, and general wastes that are being co-mingled with infectious materials, shall be placed in three (3) mil thick or equivalent strength waterproof, tear resistant, and non-chlorinated plastic bags, which shall be tied tightly, and then contained and sealed securely in corrugated cardboard boxes or an equivalent rigid outer shipping container.
Þ All containers of Special Medical Waste must be clearly and visibly labeled with the Generator’s identification number (SMW number), the words “Special Medical Waste” and the universal BIOHAZARD symbol.
CERTIFICATIONS - Generators and transporters of Special Medical Waste in and to the State of Maryland are subject to the following registration requirements:
Þ Generators and transporters of Special Medical Waste (SMW) and operators of Designated Facilities in the State of Maryland are required to obtain a Maryland Special Medical Waste Identification Number (SMW number) from the Maryland Department of the Environment (MDE), in order to treat, store, dispose of, transport or offer SMW for transportation.
Þ Special Medical Waste transporters who collect SMW in the State of Maryland or deliver it to a Designated Facility for treatment and disposal in the State of Maryland, are required to have a Maryland Special Medical Waste Hauler Certificate (SMH number) issued by the Maryland Department of the Environment. A certificate must be displayed prominently on all vehicles used for transporting SMW from a Generator located in the State of Maryland or to a Designated Facility located in the State of Maryland.
FACILITY SPECIFIC REQUIREMENTS
Curtis Bay Energy processes waste that has been transported in both disposable and reusable containers. Disposable containers received at the facility include cardboard boxes, plastic sharps containers and fiber drums. Reusable containers include 211-gallon plastic carts on wheels and a variety of smaller plastic containers, up to approximately 150 gallons in volume. Proper closure and loading of all containers is essential to prevent infections materials from being released during transport and unloading at Curtis Bay Energy. Specifically, the following requirements must be met:
Þ Reusable carts must have their lids closed before they are loaded on trailers. If lids are not closed during transport, waste may be released in the event of load shifting or a vehicle accident, and may be hazardous for personnel at Curtis Bay Energy to handle.
Þ Loose waste should be placed in 3 mil (or thicker) plastic bags before being put into the reusable carts. Shipping un-bagged loose waste is a violation of federal regulations. Loose waste is difficult to confine when the carts are being emptied into the waste-to-energy hopper and tends to stick to the inside of the carts, which impairs the operation of the cart washer.
Þ The reusable carts should not be overloaded. The typical net weight of waste in a cart is between 90 and 100 pounds. Carts that are overloaded may be permanently damaged, may release infectious material during transport, and may be hazardous for personnel at Curtis Bay Energy to handle.
Þ A load of filled, reusable carts must be properly secured in a truck or trailer before shipment. If the load is not secured it may shift, causing carts to tip over and release waste.
Þ All waste and potentially infectious materials must be kept within the carts. If potentially infectious materials are on the outside surfaces of the cart, waste handlers at Curtis Bay Energy will be put at risk of exposure.
Þ The typical weight of boxes of SMW is approximately 25 pounds. Boxes should not be loaded to more than 50 pounds, the manufacturers design weight limit. Excess weight stresses the boxes, which may cause failure and release of infectious materials. It also makes unloading boxes at Curtis Bay Energy very strenuous, which can result in back injuries for waste handlers.
Þ Liquid wastes (or frozen wastes that, once thawed, become liquid or semi-liquid) must be properly contained in a leak-proof primary receptacle before being loaded in boxes. If not properly contained the liquids leak out and soak the boxes, causing them to collapse. This leakage exposes waste handlers at Curtis Bay Energy to potentially infectious materials and promotes putrefaction of the waste in the trailer.
