Regulated Medical Waste vs. Ordinary Trash

Most people never think about where blood-soaked carpet or a used needle goes after cleanup. Businesses, property managers and agencies sometimes have to, especially when they discover that a staff member put contaminated material in a dumpster. This guide explains what makes waste "regulated," who sets the rules, and what that means in practice.

What regulated medical waste is

EPA describes medical waste as a subset of waste generated at health care facilities, such as hospitals, physicians' offices, dental practices, blood banks, veterinary clinics and research labs, that may be contaminated by blood, bodily fluids or other potentially infectious materials. It is often called regulated medical waste.

In workplaces, OSHA's Bloodborne Pathogens standard defines regulated waste more specifically. It includes:

• Liquid or semi-liquid blood or other potentially infectious materials
• Contaminated items that would release blood or such materials in a liquid or semi-liquid state if compressed
• Items caked with dried blood or such materials that could release them during handling
• Contaminated sharps
• Pathological and microbiological wastes containing blood or other potentially infectious materials

The "would it release fluid if squeezed" and "would dried material flake off when handled" tests are a practical way to think about it. A bandage with a spot of dried blood typically does not meet those tests. A carpet pad soaked with blood does.

Who regulates it

According to EPA, medical waste is primarily regulated by state environmental and health departments. EPA has not had specific authority over medical waste since the federal Medical Waste Tracking Act expired in 1991. Other federal agencies also play roles: OSHA covers worker protection, including how regulated waste is contained and labeled in the workplace, and the U.S. Department of Transportation regulates how it is packaged and transported on public roads. Local governments and landfills can add their own rules.

Because of this layered system, rules differ from state to state, including how waste must be treated before disposal, whether transporters must be registered, and what records must be kept. EPA advises contacting your state environmental agency first.

How it differs from ordinary trash in practice

Containment

Regulated waste goes into closable, leak-resistant containers. Sharps go into puncture-resistant, leakproof sharps containers. Ordinary trash goes into a regular bag or bin.

Labeling

Under OSHA's standard, containers of regulated waste in the workplace are labeled with the biohazard symbol or color-coded red. OSHA has said employers may use red bags instead of labels in some cases, as long as employees are trained to understand the color coding.

Transport and treatment

Regulated medical waste is typically picked up by a transporter that handles this kind of waste and taken for treatment, such as autoclaving or incineration, before final disposal, under state rules. Ordinary trash goes straight to a landfill or transfer station.

Records

Many states require tracking documents or manifests showing where waste went. Ordinary trash has no such records.

Biohazard cleanup waste

OSHA has stated that waste generated by companies cleaning up blood after homicides, suicides and unattended deaths is regulated waste under its standard, and that disposal must follow federal, state and local rules. A professional cleanup company packages removed materials, such as carpet, pad, mattresses, drywall and personal protective equipment, as regulated waste and arranges proper transport and disposal. Ask any company you hire how they handle waste and whether they can provide documentation. See our guide on questions to ask before hiring.

Household sharps

Needles and lancets used at home by people managing their own health conditions are treated differently in many places. The FDA recommends putting used sharps immediately into a sharps disposal container, keeping it away from children and pets, replacing it when about three-quarters full, and then following your community's disposal guidelines. Options may include drop-off sites at pharmacies, hospitals, health departments or fire stations, household hazardous waste collection, mail-back programs and special pickup services. Your local trash service or health department can tell you what is available. Needles found discarded on a property are a different situation; see our guide on needles found on property.

Common mistakes

• Putting blood-soaked materials from a workplace incident in a regular dumpster
• Putting loose needles in trash bags, where they can injure sanitation workers
• Using unlabeled bags for regulated waste in a workplace
• Assuming that because something has dried, it is no longer regulated
• Hiring a cleanup provider without asking how waste will be disposed of

What about animal remains, sewage and drug residue?

Not every kind of cleanup waste falls into the regulated medical waste category. Sewage-contaminated materials, rodent droppings, animal carcasses and materials contaminated with drug residue each have their own considerations, and the rules depend on the state and on what the material is. Some are handled as ordinary solid waste once properly bagged; others have specific requirements. Materials from a former drug manufacturing site may be governed by state drug-lab cleanup rules. A cleanup company should be able to tell you which category the waste from your job falls into and how it will be handled.

Questions to ask about waste on any cleanup job

• Which of the removed materials will be handled as regulated waste?
• How will it be packaged and labeled while on site?
• Who transports it, and where is it taken for treatment and disposal?
• Will I receive any documentation showing it was disposed of properly?

For businesses and agencies

If your employees generate regulated waste, even occasionally, your exposure control plan should describe how it is contained, labeled and disposed of. Smaller generators who do not produce it routinely often rely on their cleanup vendor to handle waste from incidents. See our guide on workplace bloodborne pathogen basics.

When to call a professional

When an incident leaves blood-soaked materials, sharps or other potentially infectious waste, a professional cleanup company can package and dispose of it properly. New Dawn Bio Restoration packages contaminated materials removed during cleanup. Contact us or call 615-914-0790, and please confirm availability for your location.

Related services

• Blood cleanup

  Removal and disinfection of blood and the materials it has soaked into, whether the spill is small or large, recent or days old.

• Commercial and workplace biohazard cleanup

  Biohazard cleanup for offices, retail stores, restaurants, warehouses and other workplaces, planned around staff safety and operations.

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