If you manage a medical practice, facility, or lab, you will need to decide on the best way to manage your medical waste treatment and disposal. There are two options to choose from.
Hire a third-party carrier, or hauler, to pick up your medical waste, transport to their centralized facility, perform waste treatment, and finally dispose by way of landfill or incineration. Pick ups are coordinated either by schedule cadence or by on-call transactions. Both manners will involve the storage of contaminated waste, prior to pick-up, in a secure area within the generator’s facility.
Select a state-approved onsite-treatment solution, allowing medical waste to be immediately sterilized, at your convenience and place of business, and then dispose of a municipal trash. (More information on this can be found here.)
Below are highlights of what you should be aware of when selecting a third-party hauler as your disposal option.
It is important to note that when a transporter picks up your medical waste, no matter what form or contract is arranged and signed, in the eyes of the law, it is the medical waste generator (you) who has “cradle to grave” responsibility.
This means that no matter what goes wrong on the third-party’s end, you can be held liable by government entities and/or by the hauler who may seek indemnification for any fines they incurred in transporting your waste.
Travel and Manifestations
The Environmental Protection Agency (EPA) and the U.S. Department of Transport (DOT) jointly developed the regulations all medical waste transporters must follow.
Your transporter should have an EPA ID number that is unique to their business as a whole. That number is used by all of their trucks during the manifest process.
Your transporter is obligated to follow the EPA’s hazardous waste manifest system, follow specific guidelines in the event any accidental spills occur, and follow all regulations as outlined by the Pipeline and Hazardous Materials Safety Adminstration.
In short, with the multitude of regulatory considerations with the transport of medical waste. Although the highest level of protection is to avoid medical waste transport all together [see solution information here].
If third-party waste hauling is the selected method, an organization must perform its compliance diligence, prior to any contracting.
States primarily regulate medical waste handling, treatment, and disposal, so you should ensure your hauler is registered in your state. There can also be applicable county/local permits or registrations your hauler needs to obtain. Registration requirements vary by county, so you should require proper registration confirmation to be provided by the company’s third-party hauler.
The Occupational Safety and Health Administration (OSHA) and DOT require documented training for those involved in the handling and transport of medical waste. Each of the specific trainings also require renewals.
OSHA’s training focuses on keeping employees safe during handling. DOT’s training focuses on such things as container labeling, what to do during emergencies, and manifest processes.
Before signing a third-party contract you should be aware that hidden charges are a well-known issue in the industry. Some haulers will charge for picking up empty containers for an example. Often exorbitant fees incur for any unscheduled pick-ups you may need to organize.
Look for small print on all such costs, as well as spelled out information on what their price increase notification process is. (Please review our 6 Things to Know About Medical Waste Contracts for more information.)
Hiring a third-party transporter involves drivers. And when humans are involved, error is inevitable. There can be costly repercussions when a driver fails to make a scheduled pick-up or stops by your business outside of your business hours. There are also plain old road accidents that can occur that could open you up to liabilities.
For information on medical waste treatment and disposal you can do onsite at your office or facility, please see below.