MANAGEMENT OF INFECTIOUS WASTE BY  RESIDENTIAL AND SMALL QUANTITY GENERATORS

Solid Waste Management Program fact sheet
04/2014
Division of Environmental Quality Director: Leanne Tippett Mosby
PUB188

This document provides information concerning the management of infectious waste by those generating small quantities of this waste in Missouri. This document provides general information only. Specific questions should be addressed to the Solid Waste Management Program at 573-751-5401.

Infectious waste in Missouri is regulated as a non-hazardous solid waste under the Missouri Solid Waste Management Law. Missouri law charges the Missouri Department of Natural Resources and the Missouri Department of Health and Senior Services (MDHSS) with the responsibility for regulation of infectious waste management in the state. MDHSS provides some oversight of management of infectious waste by Missouri hospitals and is also responsible for defining those wastes generated by small quantity generators that are considered infectious.

The Department of Natural Resources is responsible for regulating all other aspects of infectious waste management, including permit requirements for treatment facilities and packaging, transportation and disposal of infectious waste. It is important that anyone generating infectious waste be aware of the requirements for infectious waste management, treatment and disposal. The Missouri Solid Waste Management Law, Section 260.200-260.345 of the RSMo., and 10 Code of State Regulations (CSR) 80-7.010 provide the regulatory requirements for the management and disposal of infectious waste in the state.

Infectious Waste Defined and Residential Infectious Waste Exemption
Infectious waste is defined as “waste capable of producing an infectious disease because it contains pathogens of sufficient virulence and quantity so that exposure to the waste by a susceptible human host could result in an infectious disease.”  Types of infectious waste are Isolation wastes, cultures and stocks of etiologic agents, blood and blood products, pathological wastes, contaminated wastes from surgery and autopsy, contaminated laboratory wastes, sharps (hypodermic needles, syringes, scalpel blades), dialysis unit wastes and discarded biological materials known or suspected to be infectious.  Once infectious waste has been treated to Missouri Department of Natural Resources’ specifications, it is no longer considered infectious.

All infectious waste must be treated before disposal in Missouri, except when the waste is generated at an individual residence. Infectious waste generated at an individual residence may be disposed of in the residence’s trash, but must be properly packaged to prevent anyone from being injured or exposed to the waste. Sharps generated at a residence must be packaged in rigid, leak-resistant and puncture-resistant containers and sealed to prevent inadvertent injury to anyone coming in contact with this waste.

Small Quantity Generators of Infectious Waste
A small quantity generator of infectious waste is defined as a generator of 100 kilograms (approximately 220 pounds) or less of infectious waste per month. MDHSS has specified that infectious waste from small quantity generators includes these categories:

  1. Sharps - Hypodermic needles, syringes and scalpel blades. Sharps also include broken glass or other sharp items that have come in contact with material that is infectious.
  2. Cultures and stocks of infectious agents - This category includes all cultures and stocks of infectious organisms as well as culture dishes and devices used to transfer, inoculate and mix cultures.
  3. Other wastes - Those wastes designated by the medical authority responsible for the care of the patient (wastes generated by physician, podiatrist, dentist, veterinarian, etc.), which may be capable of producing an infectious disease.

It is the responsibility of the small quantity waste generator to determine whether the waste material generated by the facility should be considered infectious waste.

On-Site Treatment
Small quantity generators of infectious waste may treat this waste on-site to render it innocuous. Such on-site treatment of infectious waste does not require a permit or approval from the Department of Natural Resources.  For treatment of sharps, MDHSS recommends the use of a solution made up of one part common household chlorine bleach mixed with nine parts water. This solution should be poured into the sharps container and allowed to remain for approximately 30 minutes. The solution must then be carefully poured out of the sharps container and down the drain for treatment in the sanitary sewer system so that free liquid does not remain in the container. The sharps container must then be sealed prior to disposal.  For treatment of other small quantities of infectious waste, this water/bleach solution may be used to kill the pathogens and render the waste no longer infectious.  Ensure that the waste material is in contact with and soaked in the solution for the allotted time, then pour the solution out of the waste container.

Packaging of Infectious Waste
With the exception of sharps, if small quantity generators treat their infectious waste prior to packaging, the waste may be placed in bags and tightly sealed.  Even after treatment, sharps must still be placed in rigid, leak-resistant, and puncture-resistant containers and sealed.  Leak- resistant containers are those that are closable, with a tight fitting lid, and are leakproof on the bottom and sides.  This is to prevent any accidental sticks by the sharps to those handling the containers during transport and disposal.

If the small quantity generator does not treat the infectious waste prior to transport, the waste must be placed in rigid or semi-rigid, leak-resistant containers clearly marked with the universal biohazard symbol, labeled with the words “Infectious Waste” or “Biohazard Waste” and sealed. There is no color requirement for the waste container, but containers of certain colors may be used by the generator or the transporter as long as they meet the packaging requirements listed in 10 CSR 80-7.010(2). Neither plastic bags nor glass containers may be used as primary containers for transportation of untreated infectious waste. If bags or glass containers are used, they must be placed within another container meeting the requirement of rigid or semi-rigid and leak-resistant (see definition of leak resistant in the paragraph prior to this one). If glass is present, the primary container must protect the glass from breakage. If reusable containers are used during transport, they must be constructed of either heavy wall plastic or non-corrosive metal.  Each container must be cleaned and sanitized before it is reused.

Untreated sharps must be packaged in the same manner as treated sharps:  placed in rigid, leak-resistant, and puncture-resistant containers and sealed prior to transport.  Leak-resistant containers are described in the paragraph above concerning the packaging of treated sharps.

Transportation of Infectious Waste – Treated and Untreated
In Missouri, small quantity generators of infectious waste have four options for transportation of the infectious waste they generate, whether they have treated the waste or not. The first option is for those generators who treat their waste and have their regular waste haulers pick up the waste to deliver it to a landfill for disposal. The generators must complete an infectious waste treatment certificate to accompany the waste the hauler picks up and delivers to the landfill where the waste is taken for disposal. A treatment certificate is provided to the waste hauler as proof of treatment so that they do not need to have an infectious waste transporter license to haul the waste. The generator must also provide a copy of the treatment certification for the landfill’s file because no infectious waste is supposed to be allowed into Missouri landfills (unless it is generated from individual residences). This certificate provides proof that the waste was treated and could then be allowed into the landfill for disposal.

Small quantity generators choosing this treatment option must properly package the waste for transport and provide a certification document to accompany the waste container(s). In order to comply with 10 CSR 80-7.010(3), small quantity generators must provide the following information on their infectious waste treatment certificates:

A sample treatment certification is provided for your reference.

If small quantity generators choose not to treat their infectious waste, there are three options for transport and disposal of the waste. The generators may transport their infectious waste to treatment or disposal facilities. This may be done without having to obtain infectious waste transporter licenses. The generators must use their employees and vehicles for transportation, and the vehicles must be closed and secured (locked) during transport. The waste must be taken to a hospital approved to accept the waste by both the Department of Natural Resources and MDHSS or a permitted infectious waste processing facility for treatment or transfer into a truck for delivery to a disposal facility out-of-state.

The second transportation option is provided for those small quantity generators who choose to have their infectious waste picked up for transport and disposal. The generators must hire an infectious waste transporter licensed in Missouri to legally haul the waste to a treatment or disposal facility. A list of the infectious waste haulers currently licensed in the state may be obtained online at:  http://dnr.mo.gov/env/swmp/pubs-reports/Infectransporters.htm or via telephone from the Solid Waste Management Program using the contact information at the end of this fact sheet.

The last option for transport for small quantity generators is using the United States Postal Service. This option is only allowed for sharps treatment and disposal. They are allowed to be transported for treatment using the postal service as long as they meet the requirements of 39 Code of Federal Regulations (CFR) 111.

Tracking Documents and Manifest Requirements
All infectious waste that is transported for treatment and disposal must be tracked from the point of generation, through transport and treatment, and to the disposal facilities. Regardless of choice of transportation or destination of the infectious waste, the small quantity generator must prepare all tracking documents for this waste.

If the small quantity generators transport their infectious waste to approved hospitals, they must supply the receiving hospital with all the records and information they require. In addition, the generators that transport their own waste to a hospital or treatment/processing facility must prepare the tracking documents so that they comply with 10 CSR 80-7.010 and provide the following information, at a minimum:

The generators will sign the tracking manifests when the infectious waste is delivered to the receiving facilities. If the generators deliver the waste to transporters who will haul the waste to treatment or disposal facilities, the transporters who receive the infectious waste must sign the tracking documents to show proof of receipt of the waste and provide a copy of the signed documents back to the generators. If the generators deliver the infectious waste to treatment facilities, the personnel receiving the waste at the treatment facilities must sign to show proof of receipt of the waste and provide a copy of the signed documents back to the generators The generators must receive from the treatment facilities and disposal facilities copies of signed tracking documents that state the treatment and disposal dates.  The small quantity generators must keep these completed tracking manifests in their files to document their compliance with the federal and state requirements for transport of infectious waste.

Other Requirements
In addition to these state requirements, counties or municipalities may have additional requirements for management of infectious waste. Small quantity generators should contact their county and city health departments to learn of these requirements.