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Guide · Property owners, businesses, facility managers

What counts as regulated medical waste in Tennessee

'Medical waste' sounds like something only hospitals deal with, but the rules matter any time blood, body fluids or sharps need to be disposed of, including after a biohazard cleanup at a home or business. Several sets of rules overlap: Tennessee's solid waste rules, federal workplace safety rules and federal transportation rules. This guide summarizes how they fit together. Rules change and depend on the situation, so check with TDEC or a medical waste professional before relying on any of this for a specific case.

Three sets of rules

Tennessee's solid waste rules, administered by the Tennessee Department of Environment and Conservation (TDEC), govern what can go into landfills and how certain wastes must be handled first. The federal OSHA bloodborne pathogens standard, enforced in Tennessee through TOSHA, defines 'regulated waste' for workplaces and sets requirements for containers and labeling. Federal Department of Transportation rules govern how regulated medical waste is packaged when it is transported on public roads.

Each set of rules uses its own definitions. A material can be covered by one and not another, which is part of why the subject is confusing.

What Tennessee's landfill rules restrict

Tennessee's solid waste rules for disposal facilities include specific restrictions on medical waste. Sharps must be securely packaged in puncture-proof containers before they are landfilled. Cultures and stocks of infectious agents must be treated to render them non-infectious before landfilling. Bulk human blood, blood products and other body fluids, and waste with substantial free liquids of those kinds, may not be landfilled. Recognizable human organs and body parts may not be landfilled.

The rules note that items merely contaminated with blood, such as empty blood bags, bandages or soiled linens, are not covered by the bulk blood restriction. That distinction matters in practice.

Special waste approvals

Tennessee treats some medical wastes as special waste, which can require approval from TDEC's Division of Solid Waste Management before a permitted facility accepts it. Landfill operators can also refuse waste. This is one reason waste from biohazard cleanups typically goes through medical waste companies that already have the necessary arrangements, rather than to a local transfer station.

What OSHA calls regulated waste

For workplaces, the OSHA bloodborne pathogens standard defines regulated waste to include 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; and pathological and microbiological wastes containing blood or other potentially infectious materials.

OSHA has explained that this determination is not based on the actual volume of blood but on whether the item could release it. Regulated waste must be placed in containers that are closable, leakproof, and labeled or color-coded, and closed before removal. Disposal must follow applicable federal, state and local rules.

Moving waste on public roads

The Department of Transportation regulates the packaging of regulated medical waste for transport in commerce, with requirements for rigid, leak-resistant packaging and labeling. Many cleanup companies hand packaged waste to a medical waste hauler for transport and treatment, rather than transporting it themselves.

How this applies to biohazard cleanup

Materials removed during biohazard cleanup, such as blood-soaked carpet and pad, mattresses, upholstery, drywall and absorbent materials, are typically packaged on site in leakproof, labeled containers and sent for treatment through a medical waste channel. Sharps found on the property go into puncture-resistant sharps containers. Materials that are only lightly affected may be handled differently, depending on the rules and the receiving facility.

A reputable cleanup company should be able to tell you where its waste goes and who transports it. Ask.

What about households?

Households generate small amounts of medical waste routinely, such as used insulin needles and bandages. The FDA recommends that people who use sharps at home place them in an FDA-cleared sharps container right away and dispose of the full container according to community rules, which may include drop-off sites, household hazardous waste facilities, mail-back programs or special pickup. Loose needles should never go in household trash or recycling bins, or be flushed.

Large-scale contamination from a death, injury or crime in a home is a different matter from routine household waste, and it should be handled by professionals who can package and dispose of it correctly.

Businesses that produce medical waste

Businesses where medical waste is generated regularly, such as clinics, tattoo studios, dental offices, veterinary practices and facilities with first aid programs, typically contract with a medical waste service and follow their exposure control plan. If you are unsure whether your business needs such a contract or a special waste approval, contact TDEC's Division of Solid Waste Management or your local field office.

Common misunderstandings

One common belief is that bagging blood-soaked material in heavy trash bags makes it acceptable for household trash. Tennessee's landfill restrictions and the realities of waste handling make that a poor idea: bags tear, liquids leak, and sanitation workers are exposed. Another is that dried blood is no longer a concern. OSHA's definition of regulated waste includes items caked with dried blood that could release it during handling.

A third is that a small amount of blood never matters. OSHA treats the question as whether an item could release blood or other potentially infectious materials, not how much is present. Small spills on hard surfaces in a home can usually be cleaned with gloves and an appropriate disinfectant, but soaked porous materials are a different matter.

Why it matters

Improper disposal can expose waste workers and the public to bloodborne pathogens and to sharps injuries, and it can violate state and federal rules. Following the rules protects the people who handle waste after it leaves the property, and it protects property owners and businesses from liability.

Where to check

For current Tennessee rules, contact TDEC's Division of Solid Waste Management. For workplace requirements, see the OSHA bloodborne pathogens standard and TOSHA. For transport, see the DOT hazardous materials regulations. A medical waste hauler can also explain what it accepts and how it must be packaged.

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Call 615-914-0790 or email contact@newdawnbiorestoration.com. We serve Middle Tennessee.

This page is general information, not legal, medical, or insurance advice. Requirements change; verify with the agency listed before acting.

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