Are You Over-Classifying Your Laboratory Waste?
California has some of the most stringent environmental regulations in the U.S. Navigating the various regulatory requirements of OSHA, DTSC, CDPH and local authorities can be quite daunting and confusing. Without investing countless hours in reading the various regulations, most EHS professionals rely on their contractors, such as consultants and transporters, to keep them in compliance. In my years of experience in this industry, I’ve learned most life sciences facilities tend to over-classify their waste streams in lieu of doing a proper waste determination. One waste stream that is quite often over-classified is biological waste produced in laboratory settings. The Medical Waste Management Act specifically states the following are NOT Medical Waste under Section 117700:
(a) Waste generated in food processing or biotechnology that does not contain an infectious agent, as defined in Section 117675, or an agent capable of causing an infection that is highly communicable, as defined in Section 117665. (b) Waste generated in biotechnology that does not contain human blood or blood products or animal blood or blood products suspected of being contaminated with infectious agents known to be communicable to humans or a highly communicable disease. (c) Urine, feces, saliva, sputum, nasal secretions, sweat, tears or vomitus, unless it contains visible or recognizable fluid blood, as provided in subparagraph (C) of paragraph (1) of subdivision (b) of Section 117690. (d) Waste which is not biohazardous, such as paper towels, paper products, articles containing nonfluid blood and other medical solid waste products commonly found in the facilities of medical waste generators.Section 117675 defines an “infectious agent”:
“Infectious agent” means a type of microorganism, bacteria, mold, parasite or virus, including, but not limited to, organisms managed as Biosafety Level II, III or IV by the federal Centers for Disease Control and Prevention, that normally causes, or significantly contributes to the cause of, increased morbidity or mortality of human beings.Section 117665 defines “highly communicable”:
“Highly communicable diseases” means diseases, such as those caused by organisms classified by the federal Centers for Disease Control and Prevention as risk group 3 organisms or higher.What I’ve found is that most life sciences facilities are placing this material into red bags and managing it as a medical waste. Doing this results in unnecessary hard and soft costs, including but not limited to the purchase of red bags, increased disposal costs, regulatory oversight and more frequent inspections. ACT can assist with proper classification and disposal of this type of waste. We realize most facilities are managing it as red bag because they don’t want it going to the municipal landfill due to liability concerns. Because we understand our clients’ need for discretion, we do offer waste-to-energy treatment options that can assist you in keeping your liability and landfill impact low, all the while limiting your regulatory burden. If, like most professionals, you hate the idea of wasted (pun intended) resources, reach out to us today and find out how you can manage this material more efficiently. We’re here to help! - Vanessa Loetell, Strategic Account Manager
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