Most clinical laboratories generate three types of waste: normal waste (non-contaminated trash), hazardous (chemical) waste, and regulated medical waste (RMW), which includes biohazardous waste and sharps. Thus, 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 be a review of that written program to make sure it addresses current regulatory mandates as well as overall best practices. 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 management activities.
One of the best ways to differentiate waste streams in the laboratory is to ensure they remain separate beginning at the point of generation. Some lab managers find that it is simpler to utilize only one kind of waste container in the department rather than educate staff to correctly dispose of waste into different receptacle types. This often means that regular waste is being disposed of into biohazard containers or sharps containers. While this practice may be deemed safe because biohazardous materials would not be accidentally placed into a regular waste stream (an action that would violate regulatory mandates, and should violate internal P&Ps), it is extremely costly.
In order to maintain a program wherein the waste streams are properly segregated—thereby suppressing costs while also conforming to regulations and protecting staff and patients—there are specific methods that can help staff differentiate between the multiple waste streams created in the laboratory. For example, OSHA’s Bloodborne Pathogens Standard contains specific mandates that help convey to lab staff the purpose of the biohazardous waste receptacles (see SIDEBAR). Containers for RMW must be marked with fluorescent orange or orange-red labels with lettering and a symbol indicating the contents as biohazardous. Red bags or red containers may be substituted for the labeled bins, and these can be beneficial, as they are a clear visual guide to direct staff to the correct lab waste stream—red bins or bags are for biohazard waste only. Many laboratories also use yellow trash bags for disposal of hazardous (chemical) waste and for the disposal of supplies used for the clean up of a chemical spill. When color-coding is used for waste disposal, OSHA expects that staff is trained on the meaning of the color codes.
Develop P&Ps First, Then Audit
If your facility or laboratory does not currently have formal P&Ps detailing proper disposal of the various wastes generated, it will be important to create these and educate staff before any valid waste stream audits can be performed. To begin this process, closely analyze the lab’s current waste practices and observe and talk to staff about their waste handling habits. It is not necessary for the laboratory to have individual waste stream procedures; rather, the written P&Ps may be embedded in other lab policies that relate to waste generating activities. Furthermore, information about RMW and sharps disposal might be part of the laboratory’s exposure control plan, and directions for chemical waste handling may be placed in the required chemical hygiene plan.
Daniel J. Scungio, MT(ASCP), SLS, CQA(ASQ), has over 20 years experience as a certified medical technologist. Dan is 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. As ‘Dan the Lab Safety Man,’ he is also a laboratory safety consultant and educator. He received his BS in medical technology from SUNY at Buffalo.
A Sample of OSHA’s Bloodborne Pathogens Standard (1910.1030)1
When other potentially infectious materials… are present in the work area or containment module, a hazard warning sign incorporating the universal biohazard symbol shall be posted on all access doors. The hazard warning sign shall comply with paragraph (g)(1)(ii) of this standard.
All bins, pails, cans, and similar receptacles intended for reuse which have a reasonable likelihood for becoming contaminated with blood or other potentially infectious materials shall be inspected and decontaminated on a regularly scheduled basis and cleaned and decontaminated immediately or as soon as feasible upon visible contamination.
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