Management of Infectious Waste by Small-Quantity Generators

Waste Management Program fact sheet
Division of Environmental Quality Director: Ed Galbraith

This document provides information concerning the management of infectious waste by businesses who generate small quantities of the waste. The document provides general information only. Specific questions should be addressed to the Waste Management Program at 573-751-5401.

What is Infectious Waste?

Infectious Waste is a waste that is capable of producing an infectious disease because it contains strong and numerous enough pathogens that someone who comes in contact with it could get an infectious disease from it.

Infectious waste in Missouri is regulated under the Missouri Solid Waste Management Law by the Missouri Department of Natural Resources and also by the Department of Health and Senior Services. This fact sheet will only address the Department of Natural Resources’ requirements for infectious waste management. The Department is responsible for regulating aspects of infectious waste packaging, transportation, manifesting or tracking, disposal, and permitting of infectious waste treatment facilities. It is important that anyone generating infectious waste be aware of and comply with these requirements. The Missouri Solid Waste Management Law, Sections 260.203 and 260.204 of the Revised Statutes of Missouri deal with infectious waste, and 10 Code of State Regulations (CSR) 80-7.010 lists the regulatory requirements for the management and disposal of infectious waste in the state.

Although there are three different categories of generators of infectious waste:  individuals, small-quantity generators, and large-quantity generators, this fact sheet addresses only the requirements for small-quantity generators of infectious waste.

Are You a Small-Quantity Generator 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. This waste may be generated daily, such as that in a doctor’s office, or all at one time, which may occur when a business works on behalf of an individual providing infectious waste cleanup services at a residence. The Department of Health and Senior Services has specified the wastes listed below must be managed responsibly. Even if a business generates less than 220 pounds of the wastes listed below, the waste is still considered infectious and must be managed per the statutory and regulatory requirements:

It is the waste generator’s responsibility to determine whether the wastes generated are considered infectious per the Missouri Solid Waste Management Law and regulations. If the determination is made that the waste is infectious, the small-quantity generator must either treat the waste to render it no longer infectious or transport the waste to a permitted treatment or disposal facility. There are four management options the small-quantity generator may choose to use to accomplish this goal; they are described below.

Waste Management Options for Small-Quantity Generators

Mail-Back Program for Sharps -  Although this option is only for sharps treatment and disposal, a small-quantity generator that produces sharps may mail this waste to any company permitted to accept sharps via the mail and treat them. It is the generator’s responsibility to find such a treatment company, and pack the sharps in containers that meet requirements of the Missouri Solid Waste Management regulations and those of the U.S. Postal Service. The sharps must be mailed through the U.S. Postal Service and not through any private delivery service (such as the United Parcel Service or FedEx Corporation). The waste generator should keep records of all the infectious waste that is mailed out for treatment to be able to provide proof of proper treatment and disposal of the waste.

Treat Infectious Waste On-Site -  Each small-quantity generator may treat the infectious waste produced on the premises without having to obtain an infectious waste processing facility permit. The Department of Health and Senior Services has recommended the use of a bleach solution for the treatment of sharps (a type of infectious waste); the solution consists 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. After that time, carefully pour the liquid out of the sharps container and down the drain for treatment in the sanitary sewer system so that no liquid remains 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 completely soaked in the solution for the allotted time, then pour the solution out of the waste container.

A small-quantity generator such as a biohazard or “crime-scene” cleanup company may employ a biocide registered with EPA and the Missouri Department of Agriculture to kill specific infectious pathogens on surfaces, in furniture cushions, pillows, mattresses, rugs, and carpet padding potentially contaminated with the pathogens.  The cleanup company personnel apply the biocide per the manufacturer’s instructions, ensure that enough of the biocide has been applied to all contaminated areas/materials and wait the prescribed time to allow the chemical to permeate the waste so that it will kill all the different pathogens there. Once these materials are treated, they should be placed in the appropriate waste containers and tightly sealed. (See illustration; since the waste has been treated, there is no need for any colored bag to be used.)

Tied trash bag. Photo courtesy of Stericycle.
Photo courtesy of Stericycle

Even after treatment, sharps must be placed in rigid, leak- and puncture-resistant containers and sealed. Containers are considered leak-resistant containers as long as they are closable, have a tight-fitting lid, and are leakproof on the bottom and sides. This packaging requirement is to prevent any accidental sticks by those handling the containers during transport and disposal.

Before any sanitary landfill in Missouri may accept treated infectious waste for disposal, the small-quantity generator must prepare and sign a treatment certificate to accompany the waste to the landfill. In order to comply with 10 CSR 80-7.010(3), each small-quantity generator who treats infectious waste must provide the following information on the treatment certificate: A sample treatment certificate is provided for your reference at the end of this document. The waste generator should keep a copy of each treatment certificate provided to the waste hauler and landfill so that there would be a record to show proof of proper treatment and disposal of the waste.

Transport the Infectious Waste to a Treatment or Disposal Facility -  A small-quantity generator may make arrangements with either a hospital or a permitted infectious waste treatment or disposal facility to accept and treat the generator’s waste. Prior to transporting the waste, the generator must make sure the infectious waste is packaged per 10 CSR 80-7.010(3). Please note that the regulations require any bagged infectious waste to be placed into a rigid or semi-rigid container prior to transport.  The generator may transport the waste without having to obtain an infectious waste transporter license, but the waste must be transported directly from the generation site to a permitted treatment or disposal facility (or hospital) for treatment, and the vehicle must be closed and secured at all times until the waste is dropped off. The generator should keep records of the infectious waste taken to the hospital or treatment facility for treatment and eventual disposal to be able to provide proof of proper treatment and/or disposal.

Hire a Licensed Infectious Waste Transporter -  A small-quantity generator may contract with a licensed infectious waste transporter to haul the infectious waste to a permitted treatment and/or disposal facility. An infectious waste transporter must obtain a hazardous waste transporter license from the Missouri Department of Transportation. Information about the license, including the application process, is provided on the Department of Transportation’s website.

Licensed infectious waste transporters usually provide packaging materials to the generator so that the waste will comply with regulatory requirements, but if that is not the case, it is the waste generators’ responsibility to ensure the waste is packaged per 10 CSR 80-7.010(3). Once the waste is properly packaged, the transporter will pick up the packaged waste from the generator, transport it to a permitted infectious waste treatment or disposal facility and, after treatment or disposal, provide the waste generator with copies of manifests or tracking documents that prove the waste had been treated and disposed of per the regulatory requirements. If a small-quantity generator wishes to hire one of these transporters, the Department maintains a list of licensed infectious waste transporters online for reference and use.

As mentioned above, infectious waste that is transported for treatment and disposal must be tracked from the point of generation, through transport and treatment, to a permitted disposal facility.  Regardless of the choice of transportation or destination of the infectious waste, the small-quantity generator must prepare all tracking documents for the waste, ensure the waste transporter and permitted treatment/disposal facility returns completed manifests for each load, and maintain records of all infectious waste sent off for treatment and disposal.

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 local government agencies to see what requirements, if any, govern infectious waste management and disposal.

Sample Treatment Certificate

Treated Infectious Waste Certificate

Generator/Treatment Facility

Name _____________________________________________________

Address __________________________________________________________________________

Mailing Address ____________________________________________________________________

Telephone Number with Area Code ________________________________________________________________________

Waste Description

____ Sharps in metal containers

____ Sharps in heavy gauge plastic containers

____ Incinerator ash

____ Laboratory wastes in autoclave bags

____ Other (please specify) ___________________________________________________________

Treatment Method

____ Steam sterilization

____ Incineration

____ Chemical Sterilization

____ Other (please specify) ___________________________________________________________

I certify that the aforesaid infectious waste has been managed in accordance with the Missouri Solid Waste Management Law and respective rules and that it may now legally be placed in a sanitary landfill.

Generator/Treatment Facility Manager, Officer or Agent (please print)