In the majority of hospital and medical reference laboratories, several types of laboratory processes transpire simultaneously, each of which tends to generate some form of waste constituting various levels of hazard. Ideally, an efficient, well-run lab should be able to easily identify all of the separate waste streams from the point of generation to the point of removal from the building, and documentation should enable tracing of that waste to its point of final disposal. When it comes to accounting for this process, it is the laboratory manager’s responsibility to remain aware of the type, volume, and storage of all laboratory waste from the cradle to the grave, to use a popular phrase.
Medical laboratories generally must contend with three major waste types: non-contaminated waste (regular trash), regulated medical waste (RMW or biohazardous waste, including sharps), and hazardous (chemical) waste. The waste generated in the various lab specialty areas also differs based on the processes in which it is generated. Consider the differences between chemical waste produced in the cytology laboratory from staining specimens versus the mixed tissue and formaldehyde waste generated in the histology laboratory. Regardless of how medical laboratory waste is produced, handled, and disposed of, poor management of this waste can pose significant risks not only to laboratory staff, but also to anyone who handles it through its final disposition.
Risks of Lab Waste Exposure
The types of medical laboratory waste that are potentially hazardous to laboratory, supply chain, and environmental services staff can have significant consequences in the absence of proper management. Sharps-related injuries and punctures, blood or body fluid and skin or mucous membrane contamination, and chemical exposure (including splash exposure and the rare ingestion) are just a few of the kinds of negative incidents that can occur, even when utilizing sound laboratory practices. These events could lead to medical follow-up for conditions such as hepatitis, HIV, and other health issues that can be caused by hazardous chemical exposure.
These risks also tend to be compounded for staff outside of the lab, as they are often unaware of what they are handling and the corresponding hazards it may pose. Environmental services employees who empty trash bins or handle containers at the facility waste collection area may be exposed to sharps, chemicals, or blood borne pathogens if improper practices are followed. Contract staff that transport waste to landfill disposal sites and incinerators also are at risk for contact and exposure to hazardous pathogens. These conditions imply that while lab staff may be better protected from exposure due to their working knowledge of hazardous substances created or transferred from lab processes, those outside the lab do not share this same protection. Besides, hazard awareness alone does not automatically confer protection from injury.
Instill Waste Education Through Training
Due to the number of complicated processes and waste types associated with a robust laboratory waste management program, maintaining proper oversight while also ensuring the highest level of safety for all employees through education and training can be a challenge. One method to break such a program down into manageable pieces is to begin by looking at the waste streams separately and focusing on developing proper staff habits.
Non-Contaminated Waste (Regular Trash)
In most states, waste is considered non-contaminated if it is not visibly saturated with blood or body fluids, or has not come into contact with blood or any other potentially infectious material. Some examples include disposable personal protective equipment (PPE), such as gloves and lab coats, and wrappers and other paper products. While this waste stream may seem to be a low priority, the management of non-contaminated waste is important, especially given the number of opportunities for this waste to be comingled with contaminated waste. Some laboratory managers have gone so far as to remove regular waste containers from the department altogether in order to prevent the accidental disposal of biohazards into a non-contaminated waste stream. The reasoning behind this is, if contaminated waste identified as non-contaminated is discovered at a landfill, the contracted handler or governing body may have the authority to levy a fine against the generating facility. Many states do not allow any item with a biohazard symbol to be deposited with regular trash, even if it is an unused item (such as a specimen bag), as those misplaced items also may lead to penalties.
Rather than removing regular waste containers from the lab, many laboratories have chosen to instill proper staff education to foster a culture of safety and environmental responsibility. Unlike non-contaminated trash, RMW is usually removed from a facility by a licensed waste handling company, and the charge for such services is calculated by the total weight of the trash. If a lab places all of its regular trash into RMW containers, that department is responsible for what will surely be elevated costs to the facility. Thus, in order to get the most out of your RMW contract relationship, be sure your staff recognizes the difference between waste streams and can clearly identify where specific waste products should be placed. Initial and periodic retraining and education will go a long way in accomplishing this goal.
Regulated Medical Waste (RMW)
RMW comprises biohazard-contaminated waste and medical sharps. Proper management of this particular waste stream can have the greatest effect on decreasing waste-associated costs and maintaining a high level of employee safety in the laboratory. While the proper disposal of contaminated sharps helps prevent needle sticks and other exposures, truly safe practices must go beyond trash placement. Sharps containers should be emptied whenever they become between two-thirds and three-quarters full (or up to the manufacturer fill limit). Wide openings on RMW sharps containers should be avoided or covered in order to prevent exposures due to staff reaching inside or to prevent items from accidentally bouncing out or splashing contents back at the employee. It is also prudent to educate and train staff that regular trash is not to be placed into sharps containers. The cost for treatment of these containers (often incineration) can be up to eight times more than that of bagged RMW, and that cost, too, is calculated by weight.
Remember, laboratory waste (non-sharps) that is not visibly contaminated with blood or body fluids can be considered regular trash and does not need to be disposed of as RMW. While you must check with your state and local regulations before making RMW disposal decisions, this general rule can help reduce the amount of RMW produced by the lab. Used plastic transfer pipettes, gauze, gloves, and even disposable lab coats may be placed into regular trash where permitted (ie, when clearly uncontaminated). Again, reinforcing education on the impact of improper practices will reap dividends for the lab and the facility as a whole.
Hazardous (Chemical) Waste
Hazardous waste is generated at many points in the laboratory, and its handling and treatment are regulated by multiple agencies including OSHA and the Environmental Protection Agency (EPA). Facilities that create chemical waste must register with the EPA in one of three generator categories—conditionally exempt small quantity generator (CESQG), small quantity generator (SQG), or large quantity generator (LQG). Each category is based on the amount of waste generated on a monthly basis by the facility, and the regulations for handling the waste vary depending on the category (see TABLE 1). Accordingly, it is important to be aware of your facility’s waste generator status; keep in mind that changes to lab processes may affect the status of your entire facility by increasing or decreasing the overall waste output.
From a daily operational standpoint, chemical waste in the laboratory needs to be labeled as such and providing proper storage within the facility is key. If the waste is flammable, be sure to store volumes over one gallon inside a flammable storage cabinet. The tracking of hazardous waste removed from a facility should be handled in concert with a manifest record system. Every time a contracted waste handler collects waste, they should provide the facility with an initial manifest. Once the waste has reached its final disposal (via incineration, fuel blending, or burial), a second, final manifest should be sent to the facility to be matched and filed with the original. In a hospital, the laboratory may not be the only chemical waste-generating department, so the manifest records may be kept in another department or a common area. If this is the case, be sure the document owners are managing those manifests properly. As with RMW, reducing hazardous waste production is a beneficial goal for the lab and working toward this goal can be done in a few ways. Replacing hazardous chemicals with non-hazardous versions, neutralization, and recycling are methods that can save facility expenses and also aid in environment protection.
Hazardous to Non-hazardous Conversion
One example of hazardous chemical replacement that many laboratories have undertaken involves the use of xylene, a dangerous flammable solvent. While xylene is important in many tissue-staining processes, there are now some non-hazardous substances capable of producing the same high level of tissue stain quality.
Some laboratories neutralize formaldehyde waste with a commercial neutralizer and, once treated, the solution can be poured down the drain (provided it is tested for pH and aldehyde content). However, before moving to this process, the lab should check with its local wastewater treatment facility to be sure drain pouring of the treated waste is permitted.
There are many commercial recycling options available for laboratories, including those for formaldehyde, xylene, and other flammables. While maintenance is needed to ensure proper use of these recycling units, the cost savings and waste reduction for the labs using them can be quickly evident.
Effects of Waste on New Testing
Many of the safety standards put in place by OSHA and by other laboratory accrediting organizations exist for the protection of employees. For example, the components of the Bloodborne Pathogens Standard (OSHA 1910.1030) are designed to minimize exposure to infectious blood and body fluids. Likewise, the Chemical Hygiene Standard (OSHA 1910.1450) helps to protect staff from exposure to harmful chemicals. While these standards, and others, generally apply to active laboratory operations, they also apply to laboratory waste handling functions.
As new laboratory technologies are developed, there are manufacturers who will seek to help reduce the amount of hazards generated in each of the lab’s waste streams. However, new testing procedures will also be developed that may generate larger volumes of waste or that may involve the use of more hazardous chemicals. A few years ago, we began a new process in our histology labs that involved the use of a fixative solution containing alcohol, formalin, and acetic acid. Use of this product prevented us from neutralizing all of our waste, thereby increasing our hazardous waste output. With new technologies continually emerging, even a simple change to a lab’s brand of staining solution may incur a waste increase.
Therefore, as a laboratory considers the addition of new testing services, the generation of waste should be part of the overall evaluation. While better, more comprehensive service to the patient and health care community at large should always be the primary driver of implementing new testing, it is important to consider all resulting practice effects and impacts, including the type and amount of waste generated.
Proper management of the multiple waste streams generated by today’s medical laboratory requires an in-depth knowledge of all laboratory practices and procedures in terms of the types of waste generated. Ensuring the efficacy of such a program requires an understanding of the necessary steps for educating staff on the safe handling and disposal of the various wastes, and also encompasses all necessary tracking of that waste after it is removed from the department and from the facility. If breaches or gaps are found in the waste disposal process at any point, questions as to who retains responsibility are concerning to all health care practitioners. Should a disposal error be made or a fine be levied against a facility because of an improper waste management action generated in the lab, assignment of accountability can be a murky process. In the eyes of the EPA, responsibility lies with the waste generator, but the ultimate, on-site responsibility varies depending on facility operations. Therefore, it is wise to gain an understanding of how your facility handles such matters now and in the future. Regardless of how each facility operates, the laboratory manager or the workplace safety designee should take a direct role in overseeing waste handling processes for the laboratory.
Daniel J. Scungio, MT(ASCP)SLS, CQA(ASQ), has over 20 years experience as a certified medical technologist. He worked as a laboratory generalist in hospitals ranging from 75 to 800 beds before becoming a laboratory manager; a position in which he served for 10 years. Dan is now the laboratory safety officer for Sentara Healthcare, a system of more than seven hospitals and over 20 laboratories and draw sites in the Tidewater area of Virginia. He received his BS in medical technology from the State University of New York at Buffalo.