United States Office of Revised
Environmental Protection Public Affairs (A-107) November 1988
, r Agency Washington DC 20460
.E684
1988
c.2
Environmental
Backgrounder 10019891
Medical Waste
ISSU6 Tne recent incidents of floating debris, garbage, wood,
and medical waste on our nation's beaches, which
resulted in beach closures throughout the summer, as
well as threats to the public health, have focused
public attention on the nation's waste management
problems. The handling and disposal of municipal solid
waste remains a major unresolved national dilemma.
The municipal solid waste situation has been aggravated
by increased use of disposables by all consumers,
including the medical profession, and a near crisis in
the availability and cost of solid waste disposal
options.
Of the 160 million tons of U.S. waste generated each
year, 3.2 million tons is medical waste generated by
hospitals. EPA estimates that 10 to 15 percent of this
hospital waste is infectious. In addition, there are
numerous other generators of small quantities of medical
waste. These include private practices, home health
care, veterinary clinics, and blood banks.
Overview
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The United States has made tremendous progress in
improving the water quality of its lakes, bays,
estuaries, and oceans by treating its municipal sewage
and industrial effluents. Billions of dollars have been
spent on the construction of sewage treatment plants,
and on the control of industrial discharges. Extensive
measures have been taken in the attempt to eliminate
"floatables," i.e. solid waste which makes its way into
the water from a variety of sources. In addition,
steps have already been taken to phase out permitted
ocean dumping.
But these measures have proved insufficient in the
face of the explosive development and growth along our
nation's coasts. An estimated 70 percent of our
population now lives within 60 miles of a coastline.
We, as a nation, have made little progress in
addressing our municipal solid waste management problems
and in fact have continued to produce more and more
solid wastes, including, of course, medical wastes.
Because of the coastal population explosion, the
problems of medical waste management and water quality
control are closely linked.
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Sources
The medical waste found this past summer on our
beaches could have been generated by a number of
sources, including illegal dumping; sewer overflow;
storm-water runoff; illegal drug users; and inadequate
handling of solid waste at landfills and coastal
transfer facilities, which includes waste from doctors'
offices, laboratories, and even legitimate home users of
syringes, such as diabetics.
While hospitals, clinics, and health-care facilities
may generate the vast majority of these wastes, there
are numerous other generators, many of which produce
only small quantities. These include private medical
and dental practices, home health care, veterinary
clinics, laboratories, and blood banks. In fact, there
may be over a million sources of medical wastes.
Individual behavior practices must change — not just by
those who knowingly litter or illegally dispose, but
also by home users of medical products and other
generators of small quantities of this waste, such as
doctors' offices. Public education is a necessary
component to instruct people on safe disposal methods.
Tracking systems alone may not prevent improper consumer
disposal of such items as disposable syringes.
Description
The 3.2 tons per year of medical wastes include a
variety of wastes, such as wrappers from bandages and
catheters, containers such as intravenous (IV) bags and
used vials, disposable items such as tongue depressors
and thermometer covers, as well as infectious wastes.
Approximately 10 to 15 percent of all medical wastes
is estimated to be "infectious" waste. EPA presently
identifies six types of waste as potentially infectious:
9 Cultures and stocks of infectious agents and
associated biologicals.
9 Pathological wastes.
9 Human blood and blood products.
9 Contaminated sharps (such as needles and
scalpels).
9 Contaminated animal carcasses, body parts, and
bedding.
9 Isolation waste.
Treatment Technologies
Of the available treatment technologies, incineration
appears to be the most utilized. EPA has data that
indicate 70 percent of hospital waste is incinerated on-
site, 15 percent is sterilized in an autoclave, and 15
percent is transported off-site for treatment. Ten
percent of the waste treated off-site is incinerated.
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Health Concerns
Certain medical wastes can be health hazards. It is
interesting to note that several studies have shown
that hospital wastes are generally less virulent than
typical domestic waste. In addition, the Centers for
Disease Control (CDC) have no epidemiological evidence
to suggest that hospital waste is any more infectious
than residential waste, or that hospital waste has
caused disease in the community as a result of improper
disposal.
Exposures to medical wastes that could result in the
transmission of disease are primarily occupational and
are most likely to occur among workers who handle these
wastes.
EPA understands the public concern about the
transmission of blood-borne disease such as AIDS from
exposure to used syringes and improperly disposed blood.
Public health officials, including the Centers for
Disease Control, believe the risk of contracting these
diseases from exposure to these wastes in the environ-
ment is extremely low. None the less, EPA believes
inadvertent exposure to such wastes is unacceptable, and
EPA is continuing to investigate these concerns to make
sure our conclusions are accurate.
ADDrOfiCh EPA believes that the use of good management and
"^ housekeeping by those who generate, transport, store,
treat, or dispose of medical waste may be the key to
reducing potential risks to the public from these
wastes. A well-designed educational program is
essential to the implementation of these practices. EPA
has already provided extensive technical support to
states and to the health care community on the proper
management of medical wastes—but EPA plans to do more.
This problem involves all levels of government; it
cuts across public health issues and local economies and
includes both solid waste management and water quality
control issues.
New Legislation
On November 2, 1988, President Reagan signed into law
the "Medical Waste Tracking Act of 1988," which requires
EPA to establish a two-year demonstration program to
track medical waste from its generation to disposal.
The program applies to New York, New Jersey,
Connecticut, and the seven Great Lakes states. Any
other state may be included in the tracking system, and
any of the ten listed states may choose to opt out of
the program. EPA strongly encourages the 10 listed
states to opt in the program, and it would welcome any
additional states that may want to opt in. States have
within 30 days of promulgation of EPA's regulation to
opt in or out of the program.
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EPA Action
Although the law gives EPA six months to promulgate
regulations, EPA plans to establish the tracking system
by February 1989. If EPA meets that schedule, states
will have until approximately March 1, 1989, to opt in
or opt out of the program. For those states that
participate in the program, the tracking system should
be in effect by May 1, 1989.
At the conclusion of the two-year demonstration
tracking program, EPA is required to submit a Report to
Congress.
Chronology
1982 -Published draft guidance for states and health
care community on infectious waste management.
1982 -Began on-going educational program by providing
instructors and speakers for continuing
education programs for health-care workers and
trade and professional association meetings
and symposia.
1986 -Published "EPA Guide for Infectious Waste
Management," which finalized the 1982 draft
guidance.
1986 -EPA announces Near Coastal Waters Strategy to
protect our overstressed coastlines.
10/87 -Issued a draft study of hospital-waste combus-
tion. The final report is due in early 1989.
11/87 -Called together a group of experts that included
representatives from the Centers for Disease
Control, the National Institutes for Health,
the American Medical Association, states, and
the Environmental Defense Fund to discuss
infectious waste management. The panel agreed
risks were primarily occupational and that
public exposures were isolated. The group also
agreed that EPA's initial efforts should be
through guidance and education.
1988 -Each region designated a Medical Waste contact
person and two consulting firms were contracted
to develop educational materials and guidance,
and to conduct studies of state programs.
4/88 -EPA, the National Oceanic and Atmospheric
Administration (NOAA), and the Department of
Transportation (DOT) begin to implement Sectior
2204 of the Marine Plactic Pollution Research
and Control Act of 1987 to educate the public
on the prevention of plastics pollution. EPA
is developing a series of fact sheets and will
share in the distribution of NCAA's materials.
5/88 -EPA began to assist New York and New Jersey with
developing a bi-state tracking system on
medical wastes, which was completed in August
1988.
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6/88 -Published a Federal Register Notice in which EPA
requested comments on issues related to medical
wastes. The comment period closed on Monday,
August 1, 1988. (See Public Action, page 6)
-Began to develop an inspection manual for
hospital incinerators and a training manual for
the operators of hospital incinerators.
-Began preparing brochures, posters, and a
bibliography of abstracts of infectious waste
studies to supplement the agency's guidance
document on infectious waste management.
Guidance materials to assist states in
implementing infectious waste management
programs under existing municipal solid waste
authorities are also under development.
7/88 -Creation of an Office of Pollution Prevention, to
maximize and focus the agency's attention on
reducing waste and pollution before it becomes
a disposal or clean-up problem.
8/88 -Creation of a task force of solid recycling in
EPA to work specifically on the national
municipal solid waste dilemma.
-Appointment of EPA Medical Waste Task Force,
chaired by Dr. John Moore, to coordinate agency
activities on medical waste.
9/88 -Region 2 hosted a Medical Waste Conference with
state health and environmental commissioners
from New York City, New York, New Jersey, Rhode
Island, Connecticut, Pennsylvania, and
Maryland.
-Federal officials from EPA, the Department of
Defense, Department of Transportaton,
Department of Commerce, National Science
Foundation, State Department, and the
Department of Interior met to discuss improved
federal sharing of enforcement and resources to
combat improper disposal of medical waste.
10/88 -EPA sponsored a two-day Ocean Pollution Enforce
ment Conference in Point Judith, Rhode Island.
Representatives of the National Association of
Attorneys General, various state and federal
agencies (including the Coast Guard and the
FBI), and the Attorneys General of the 14 East
Coast states attended. The discussions
covered a broad range of state and federal
ocean pollution enforcement issues, including
medical waste disposal.
Assessment Plan
Following is EPA's plan for dealing with solid waste
issues related to the management of medical waste. The
objective of the plan are:
1. To develop a universally accepted definition of
"medical waste" to facilitate appropriate control
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and/or regulation of this waste.
2. To evaluate the effectiveness of existing state
programs in controlling the medical waste problem,
and, in particular, to identify those components of
state programs that are successful.
3. To quantify the extent of the problem by
determining the amount and types of medical waste
that are generated, current treatment and disposal
practices, the relative contribution of each source
(doctors' offices, clinics, hospitals), and com-
pliance costs.
4. To develop the most effective means of tracking
and reporting the handling of medical waste and to
ensure the proper management and destruction of the
waste.
5. To determine which transportation, treatment,
storage, and disposal methods are most effective in
minimizing environmental release by each waste type,
and what resource requirements are required for each
method.
6. .To .determine the environmental, economic, and
health risks of improper disposal of infectious
waste.
7. To determine whether regulations are adequate
for hospital incinerators. The agency is completing
an examination of available control technologies by
the end of the year and will result in:
+ A hospital waste combustion study report.
+ A hospital incinerator operator training manual.
+ A hospital incinerator inspection manual.
8. To ensure that the general public and interest
groups are provided with the information necessary to
understand the nature of this problem, and kept fully
informed of all program developments, including
program implementation requirements. To provide
educational information for the affected industry,
regulators, and home medical product users.
Related Activities
® Coastweeks »88 (September 17 — October 10) The
Center for Environmental Education (CEE), under a
contract with EPA, coordinated a nationwide volunteer
beach cleanup of litter. The effort involvee more than
30,000 volunteers working on selected beaches in all
coastal states. Each volunteer was issued a score card
to record the frequency of many common marine debris
items. This information will be tabulated and will form
a baseline national marine debris frequency distribu-
tion. These data will represent the national marine
debris situation prior to the implementation of MARPOL,-
Annex V (international agreement to prevent pollution
from ships at sea). Hopefully, this cleanup effort will
be repeated next year to compare the current situation
to that which will exist after the MARPOL regulations gc
into effect.
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DATE DUE
Chicago, IL 6C604 ' i-0^ I
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' State Action
Public Action
9 '88 Oceans Conference (October 31 — November 2)
The Coast Guard hosted an annual conference in Baltimore
with Maryland's Governor Schaffer as chairman, and the
theme: "Partnership in Marine Interests." The con-
ference included a medical waste panel.
Most of the states (88 percent) are or will soon
regulate infectious wastes.
Thirty-one states single out packaging/labeling
requirements in their rules, such as double-bagging and
rigid containers.
Transportation controls and record-keeping are
required by three-fifths of the states.
New York & New Jersey
The New York/New Jersey area in EPA's Region II is
the area most heavily affected by the medical waste
problem.
EPA is working closely with the National Enforcement
Investigation center, the Coast Guard., and the FBI to
add federal support to state and local efforts to put a
halt to illegal dumpers and is providing direct
technical assistance to states that have recently
experienced infectious waste mismanagement incidents.
In May 1988, EPA began working with the states of New
York and New Jersey to develop consistency in their
state infectious waste programs, including implementa-
tion of a tracking system.
On August 10, 1988, the states of New York and New
Jersey enacted emergency legislation imposing a manifest
tracking system for facilities which generate more than
100 kilograms per month of medical wastes within their
states. State officials will later determine whether
smaller generators, such as doctors offices and clinics,
should be regulated as well.
As of August 1, 1988, EPA received over 100 public
comments on a notice the Agency put in the Federal
Register in June 1988 seeking comments on a number of
issues related to infectious waste. Comments were
received from trade associations, hospital groups, state
and local health departments, and interested individua-
ls. There was no evidence presented by any commentors
suggesting that properly handled and disposed infectious
waste posed a public health problem. The majority of
respondents agreed that workers in health-care faciliti-
es, transporters of infectious waste, and workers at
disposal sites run the greatest risk of exposure.
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