Managing waste generated in the clinical laboratory is a core element of an overall laboratory safety program. While there are numerous priorities in the modern clinical lab arena that demand director-level attention, such as inventory control, staffing to workload, and budget management, the reality is that an effective laboratory waste management program can positively impact each of these issues.
Some laboratories take meticulous understanding and management of waste as a point of professional pride, but the fact remains that control of lab generated waste is regulated by multiple national organizations and local authorities. While gaining an in-depth understanding of the guiding parameters and different regulatory agency standards can take time, there are good resources available to help accelerate the process.
Value of Waste Segregation
The first step in managing lab waste is to learn and differentiate the various waste streams and train staff in proper waste segregation. Mixing waste is done sometimes for convenience (it is certainly easier to not provide regular training or updates, and no attention to detail is needed if only one type of waste container is to be purchased), but this “simple” approach is expensive and can create an unnecessary environmental burden.
Clinical laboratories typically generate at least three separate waste streams: Regular (non-regulated) waste, regulated medical waste (RMW), and hazardous (chemical) waste. RMW can be further separated into biohazard waste and medical sharps. Each of these refuse streams is regulated differently, and some are overseen by multiple local and federal agencies.
Regular, non-regulated trash is considered non-contaminated and is disposed into a local community landfill. Typically the cheapest waste to remove, it is best to ensure the lab is disposing of as many permissible items in this stream as regulations allow. Most local municipalities allow the disposal of items such as gloves, disposable lab coats, plastic transfer pipettes, and gauze, as long as the items are not visibly saturated with blood or body fluids. Most of the other lab waste is removed by a third-party service provider, and those providers usually charge by weight.
Regulated Medical Waste
RMW is contaminated (eg, visually bloody) and should be placed in labeled, biohazard-specific containers with tight-fitting lids. RMW bags are usually red or orange in color, and containers for lab RMW come in a wide range of sizes. The treatment of RMW bags varies depending on the location of the facility and state laws about transport and disposition. Some health care facilities autoclave their waste and dispose of it as non-hazardous. Some RMW-handlers treat the bags with a high-heat steam process that renders the contents unrecognizable. Many RMW bags end up in biohazard landfills that require special assembly and maintenance, and are not generally considered good for the environment.
Medical sharps, another type of RMW, include needles and glass, or other items that can easily break to create a sharp edge. Glass containers, agar plates, and wooden applicator sticks are all examples of items that should be wasted into a sharps container, even if they are not broken. If placed into a plastic bag and broken during transport, they may cause an exposure for someone handling the bags downstream. Most sharps containers are removed from the lab and incinerated, and while some vendors offer recycled sharps containers, the contents are usually treated via incineration.
Placing items that do not qualify as RMW into RMW bags or sharps containers is an expensive mistake for laboratories. The added volume and weight increases disposal costs, while the use of specialized sharps containers and biohazard bags adds to the total coast of waste management. Training staff to properly segregate solid wastes plays a large role in departmental finance management and enhances personnel safety.
Hazardous (or chemical) waste is generated in the laboratory via standard work processes and is eliminated from the facility via drain disposal, recycling, neutralization, or removal by a contracted vendor. Learning how and where to dispose of the various types of clinical lab chemical waste depends on the location of generation, composition, and the designated waste generation status of the facility.
Liquid chemical waste that is disposed via laboratory drain may be routed to the local sewer system or to a facility-owned chemical tank. These collection tanks are a beneficial feature, as chemical waste can simply be poured down specific drains with no significant restrictions. The tanks are then emptied by a contracted waste disposal company. Unfortunately, these types of lab sinks and tanks are fairly uncommon in the clinical setting. Sinks connected to local sewer systems require more oversight, and the effluent from the facility may be monitored regularly by the local wastewater authority to ensure no improper chemicals (such as corrosives or carcinogens) are introduced. In some locales, the wastewater agency will conduct on-site facility waste audits, so knowing what wastes are being disposed via lab sinks is important. Local authorities may request a review of lab waste compositions (ie, an evaluation of the Safety Data Sheets) before allowing them to be sent down the drain.
Some laboratories engage in recycling hazardous wastes. Certain formaldehyde solutions, xylenes, and ethanols can be distilled for reuse. This recycling does require additional labor and equipment upkeep, but also minimizes chemical purchases and reduces overall laboratory hazardous waste output. Another chemical waste treatment that decreases waste is neutralization. Many histology labs neutralize formaldehyde liquids, a process which renders the waste safe for drain disposal.
Additional Waste Stream Considerations
Other waste streams may be created in health care laboratories that are highly regulated and expensive to manage, but are not commonly handled by clinical laboratories. Radioactive wastes should be handled in conjunction with a professional radiation safety officer (RSO). Universal waste (batteries, mercury-containing equipment, and light bulbs or lamps) is regulated by the Environmental Protection Agency (EPA) and is often managed through the facilities department. Mixed waste may contain both radioactive and hazardous waste. Handling this waste is very complex and is overseen by multiple federal and regulatory agencies. Again, it is necessary to work with the RSO to ensure the safety during handling and disposal.
Perform Waste Audits
The EPA and its state agencies have expanded hospital waste oversight in recent years and require an inspection once every five years of any facility registered as a Large Quantity Waste Generator (ie, creates over 1000 kilograms of hazardous waste per month).1 Many states now include all hospitals in these inspections, regardless of generator status. Although this decision was largely driven by changes in pharmaceutical waste regulations, the audits include laboratory departments, as well as any other area where waste is generated. In the lab, auditors review the storage, labeling, and movement of waste in and out of the laboratory, and will inspect for proper waste handling in satellite and central waste accumulation areas. Evidence of required staff training and documentation are aspects likely to be inspected.
Performing internal waste program audits can help prepare the lab for regulatory inspections and should be a part of the overall lab management program. These audits should include a physical walk-through of the laboratory and associated waste storage areas, a review of documentation (including policies and waste manifest records), and development of an action plan to correct any nonconformities discovered during the audit. Internal audits should be conducted at least annually or whenever there are major changes to laboratory waste types or volumes.
Status of Laboratory Waste Guidelines
One beneficial resource that details best practice waste management information is CLSI’s Clinical Laboratory Waste Management (GP05-A3) guidance document (see SIDEBAR). The most recent version was published in 2011, and while that may seem like a long time ago, there have not been any significant changes to lab waste processes or regulations to warrant an update.
However, new technologies are emerging rapidly and some applications generate new waste for certain clinical labs, although, these have not yet had a significant effect on lab waste handling or treatment. Liquid biopsies, for example, may mitigate tissue waste, but generate more blood waste; something labs handle every day already. DNA sequencing in genomic testing is an expanding technology as well, but the waste produced is easily managed with other hazardous waste streams. Additional new molecular testing in microbiology and other lab areas is creating new waste, but these, too, tend to fall under established hazardous or non-regulated waste streams.
Although newer lab technologies have not created major waste practice changes, the EPA has been reviewing its hazardous waste generator regulatory program and is making some alterations. The original Resource Conservation and Recovery Act (RCRA) regulations were published in 1980, and after a few formal evaluations, the agency decided to make changes to increase clarity, consistency, and flexibility for waste generators and handlers. After edits were made, a proposed rule was published in the Federal Register in 2015, and the final rule became effective in May of 2017 at the national level.2,3 States that run their own hazardous waste program (46 of 50, currently) have one year to implement the new final rule, and most are expected to do so this year.
The changes in the new regulations are complex and they cover several different aspects of the waste management program. First, some regulations will be reorganized for clarity and improved organization. Other edits provide methods for waste generators to more easily comply with regulations. Clarification is given to acute hazardous waste classifications and instructions for biennial report submissions. There are edits to the regulations that improve environmental protection, including emergency response procedures and updated container labeling requirements. Finally, further changes allow generators to maintain their status despite rare monthly waste volume increases, and waste movement from certain facilities is newly allowed. For example, a site designated as a Very Small Quantity Generator is now allowed to move hazardous waste to a separate Large Quantity Generator facility that is under the control of the same person or business. This new provision to the regulations can help labs save money by consolidating waste removal to one location.
Laboratory Waste Program Management
Regardless of regulatory agency, all lab-generated waste is considered the responsibility of the laboratory until its final disposition. When issues occur in the storage, handling, or disposal process, people may be injured, the environment may be endangered, and expensive fines can be levied. Thus, a comprehensive laboratory waste management plan is vital to the lab safety program, and if effectively operated, it should prevent such issues.
Since laboratory waste is overseen by many regulatory agencies, it can be useful to understand and utilize a number of available resources to aid in program management. Be sure to communicate with the contracted RMW and hazardous waste haulers for the facility, as they often are willing to answer questions or even provide training. Many state oversight agencies are likewise willing to provide assistance with waste issues and may provide on-site compliance audits.
A complete waste program should include procedures that are current with federal and state regulations. Staff training should occur for all waste processes; providing regular updates and competencies will help staff remain compliant. Regular waste audits help with program continuity and a successful waste management program will provide the necessary cradle-to-grave oversight to instill safety in the laboratory and beyond.
- Environmental Protection Agency (EPA). Categories of Hazardous Waste Generators. Accessed 3/19/2018. https://www.epa.gov/hwgenerators/categories-hazardous-waste-generators
- EPA. Final Rule: Hazardous Waste Generator Improvements. Accessed 3/18/2018. https://www.epa.gov/hwgenerators/final-rule-hazardous-waste-generator-improvements#rule-history
- United States Federal Register. Hazardous Waste Generator Improvements Rule. Accessed 3/18/2018. https://www.federalregister.gov/documents/2016/11/28/2016-27429/hazardous-waste-generator-improvements-rule
Daniel J. Scungio, MT(ASCP)SLS, CQA(ASQ), has over 25 years of 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. As “Dan the Lab Safety Man,” he also serves as a professional speaker, trainer, and lab safety consultant. Dan received his BS in medical technology from the State University of New York at Buffalo.
- CLSI. Clinical Laboratory Waste Management; Approved Guideline—Third Edition. CLSI document GP05-A3. Wayne, PA: Clinical and Laboratory Standards Institute; 2011
- Hazardous Waste in Healthcare: A Guide to Regulatory Compliance. James Crouch, BSBM, MHA, MSAJS, HCPro, June, 2016
- EPA website: www.epa.gov/epawaste/hazard/generation/index.htm
- US Department of Transportation. Pipeline and Hazardous Materials Safety Administration. Transportation. 49 CFR 171-179
- US Department of Labor, Occupational Safety and Health Administration. Occupational Safety and Health Standards. Waste Disposal. 29 CFR 1910.141 (a)(4)(i-ii); 1998
- US Department of Labor, Occupational Safety and Health Administration. Occupational Safety and Health Standards. Bloodborne Pathogens. 29 CFR 1910.1030; 1998
- US Department of Labor, Occupational Safety and Health Administration. Occupational Safety and Health Standards. Toxic and Hazardous Substances. Occupational Exposure to Hazardous Chemicals in Laboratories. 29 CFR 1910.1450; 1998
- Biosafety in Microbiological and Biomedical Laboratories. 5th ed. Washington, DC: US Department of Health and Human Services, CDCNIH; 2007
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