Conducting a Waste Management Program Audit

January-February 2014 - Vol. 3 No. 1 - Page #6

As a clinical laboratory manager, reviewing the particulars of the department’s waste streams is likely not among the top operational priorities on any given day. Rather, when it comes to the most pressing issues facing the typical hospital laboratory, staffing, productivity, and testing quality tend to dominate day-to-day operations, with waste handling often relegated to the back burner. Although this is understandable, the proper management of laboratory waste is an important safety issue and regulatory agencies will hold your organization accountable for any violations that have or could cause harm to your employees, the public, or the environment. 

Therefore, conducting audits of the laboratory’s various waste streams is a highly recommended practice that will help maintain employee safety, and minimize regulatory nonconformance and potential fines. Regulatory bodies such as CMS, the FDA, and the US Department of Transportation (DOT) all have mandates for how laboratory waste should be managed and they also have deemed that oversight of such waste—from its point of creation to its final disposition—is the responsibility of the waste-generating establishment. With this in mind, there are usually three main waste streams that laboratory managers should be concerned with—normal waste (non-contaminated trash), regulated medical waste (RMW, including biohazardous waste and sharps), and hazardous (chemical) waste. Managing each stream in the most efficient way possible is the key to program success.

Conducting a Waste Audit
All clinical labs should have formal policies and procedures (P&Ps) in place for the handling and disposal of each type of waste produced in the laboratory. When approaching a waste audit, the first step should include a review of that written program. It may be that waste handling P&Ps are created and owned by areas in the facility outside the laboratory department, but lab management staff should always have access, and therefore clear guidance for waste managing activities.

Subsequent to this review, it is essential to understand your state and local regulations regarding waste disposal and transport. The codes of practice vary from state to state, so gaining knowledge of your particular state’s requirements is key. Likewise, a list of guidelines and requirements can be obtained from local waste authorities. The next steps in the auditing process vary based on the type of waste stream being examined.

Regular Waste
Auditing the regular (non-contaminated) waste stream is a fairly straightforward, but important task. In most areas of the United States, items that are visibly dripping with blood or body fluids (saturated) cannot be placed into regular trash containers. Looking for such items (including sharps) that may have been placed accidentally into non-contaminated waste receptacles should be a part of the audit process. Using clear bags in regular waste containers can facilitate this activity, but a careful eye is needed, as RMW may easily be covered by regular trash. In some states, specimen bags, packaging, or any other items that display the biohazard symbol (see Figure 1) may not be disposed of in the regular waste stream. Even if the bag or packaging has never been used or contaminated, it must be disposed of as RMW. 

Educating laboratory staff about proper waste disposal should certainly include information about the potential consequences of inadvertently disposing of RMW with regular laboratory waste. If RMW is discovered in a landfill designated for non-contaminated trash, the laboratory or facility responsible will be fined. There are extensive costs associated with remediating such errors, including expenses imparted for decontamination of the landfill. There also are safety considerations when waste is improperly disposed. Accidental sharps injuries and bloodborne pathogen exposures may lead to medical follow-up for conditions such as hepatitis, HIV, and other health issues for a person exposed to unexpected RMW anywhere in the waste handling process.

Regulated Medical Waste
When auditing for RMW, the features of waste containers becomes more of an issue. Any receptacle used for RMW must be closable, must contain all contents within the enclosure, and must display proper labeling. These receptacles also must prevent leakage of fluids during handling, storage, transport, and shipping.1

Sharps containers should be audited to ensure they also are closable, puncture-resistant, and leak-proof. Sharps containers should be placed so that they cannot tip over while in use. For some container types this can be accomplished by utilizing a cart or other separate stabilizing device.2 It is important to emphasize that sharps containers should never be overfilled, as this can create exposure hazards for staff. Most manufacturers define a fill limit on the container, but if not, the container should never be more than between two-thirds and three-quarters full. 

Separation is key, so be sure your staff knows that regular trash should never be disposed of into RMW containers. Remember that RMW disposal is charged by weight, and it is far more costly than regular trash disposal. Furthermore, there are environmental concerns associated with improper disposal, as sharps containers are normally disposed of via incineration, so overutilization of these receptacles leads to increased air pollution. Likewise, unnecessary use of biohazard bags for all trash increases the size of specialized landfills designed for that type of waste.

Hazardous Waste
Processes in the laboratory that generate hazardous chemical waste are often complicated and auditing this waste stream requires a solid understanding of those processes, as well as knowledge of the regulations surrounding them. What follows is a general overview and does not represent a complete, detailed review procedure. A hazardous waste audit should have two components—a physical inspection and a thorough review of paperwork associated with the waste.

Physical Inspection Audit
During the physical inspection, all areas of the facility where laboratory waste is or potentially could be stored should be evaluated. This includes any areas outside the department, such as a facility-designated hazardous materials storage shed, a separate central accumulation area (CAA), or even the morgue, if it is used for such purposes. Check to see that these areas have easy access to adequate spill cleanup instructions and supplies in the event of an accidental waste release. If waste is held in an outside storage building, ensure that secondary containment exists and is sufficient. 

Containers stored in a facility’s CAA should be clearly labeled as Hazardous Waste and specific dates should be listed on the label—dates indicating when the container was first used and when it became full (if applicable) should be visible. It is important to verify the waste has not been stored for too long; a facility that is registered as a large quantity waste generator (LQG) can store full hazardous waste containers in a CAA for up to 90 days, whereas a small quantity generator (SQG) has up to 180 days before removal is required. 

Of course, the physical audit of the hazardous waste stream should include a walk-through of the laboratory. In this area, small chemical waste containers do not require special labeling unless they are being transferred to a nearby satellite accumulation area (SAA) or to the CAA. In that case, they need to be labeled as Hazardous Waste. These small containers should remain closed or capped throughout the day, except when waste is being deposited. Open containers greatly increase the chance of a spill or even an accidental release into a sink or drain. If flammable waste is kept in the laboratory, volumes over one gallon should be stored inside a designated flammable cabinet.

Paperwork Audit
Key among the paperwork that needs review in a hazardous waste audit is the waste manifest. A manifest is a form prepared by all generators who transport hazardous waste for off-site treatment, recycling, storage, or disposal. The form is designed to enable the waste generator to verify that its waste has been properly delivered and discarded. The generator will receive an initial manifest prior to waste removal, and a final one when the waste is disposed of. The final manifest should be matched with the initial manifest for record keeping and these files should be kept on site for three years. If the facility is a LQG and utilizes a CAA, weekly inspections of that CAA need to be documented as well, and should include a close review of the waste containers for deterioration, leaks, and proper labeling. 

Additional Audit Tips
Deciding how often to conduct waste stream audits in the laboratory is a function of an assortment of factors. First, it is important to be aware of any common issues in a given area. Conversations with staff, lab leadership, and others in the facility where lab waste is processed will bring such issues to light. Changes to lab waste handling processes also may dictate the necessity for an audit to ensure new practices are being followed. As laboratory mangers should be conducting regular safety rounds, it may make sense to incorporate waste review into this process, especially if there have been problems with waste handling in the past.

Due to the numerous facets of laboratory waste processes, use of a checklist during auditing may prove helpful. A laboratory may create a checklist based on its unique needs, or there are other, more generic checklists that can be used. One such checklist is available via the Clinical and Laboratory Standards Institute. In the document Clinical Laboratory Safety; Approved Guideline—Third Edition (GP17-A3), there is a sample laboratory safety audit (Appendix C).3 While the audit is designed for all aspects of laboratory safety, it does contain several checklist items that pertain to lab waste streams. 

Once the waste audit is performed, it will be vital to follow up on and quickly correct any nonconformances noted, especially those that may lead to improper waste disposal. Moreover, staff education should be provided if there are any changes or updates to overall waste-handling processes. As always, be sure to document any corrective action in your audit follow-up report (see examples in Figure 2).

If for any reason conducting a waste audit is simply not possible, or more education is needed, one option is to contact a contracted waste handler for assistance. Some RMW and chemical waste vendors are willing to assist in education and perform an audit for the laboratory or facility. There may be a charge for the service, but some businesses will waive the fee for their customers.

A poorly managed laboratory waste management program can easily precede employee exposures, costly regulatory fines, environmental damage, and unfavorable press. These alone are strong reasons to implement an audit program of the various waste streams. More important, however, these audits are a proactive part of an overall laboratory safety program. Prevention of disposal errors, accidental biohazard or chemical releases, and staff exposures is an effective mechanism for improving lab safety culture. Improved facility safety, regulatory accountability, and protection of staff, the public, and the environment all emphasize the need for systematic waste audits to be included in the laboratory manager’s list of priorities.


  1. OSHA Bloodborne Pathogen Standard 1910.1030(d)(4)(iii)(B)(1)(ii)
  2. OSHA Bloodborne Pathogen standard 1910.1030(d)(4)(iii)(A)(1)
  3. CLSI. Clinical Laboratory Safety; Approved Guideline—Third Edition. CLSI Document GP17-A3. Wayne, PA: Clinical and Laboratory Standards Institute; 2012.

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.


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