EPA/600/R-16/251 I October 2016
www.epa.gov/homeland-security-research
United States
Environmental Protection
Agency
&EPA
Best Practices for Management of
Biocontaminated Waste
Li1' '
, A "'t i I?
ESHR^
Office of Research and Development
National Homeland Security Center
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EPA/600/R-16/251
October 2016
U.S. Environmental Protection Agency
Best Practices for
Management of Biocontaminated Waste
Revision Number: 05
Issue Date: September 2016
U S. Environmental Protection Agency
National Homeland Security Research Center
Decontamination and Consequence Management Division
Research Triangle Park. NC
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Best Practices for Management of Biocontaminated Waste
Disclaimers
The U.S. Environmental Protection Agency through its Office of Research and Development managed the
research described here. This work was performed by Battelle under Contract No. EP-C-15-002 Task
Order 0001. It has been subjected to the Agency's review and has been approved for publication. Note
that approval does not signify that the contents necessarily reflect the views of the Agency.
The cleanup process described in these best practices does not rely on and does not affect authority
under the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA), 42
U.S.C. 9601 et seq., and the National Contingency Plan (NCP), 40 Code of Federal Regulations (CFR)
Part 300. This document is intended to provide information and suggestions that may be helpful for waste
handling efforts and waste management operations after a biological incident and should be considered
advisory. The best practices in this document are not required elements of any rule. Therefore, this
document does not substitute for any statutory provisions or regulations, nor is it a regulation itself, so it
does not impose legally-binding requirements on EPA, states, or the regulated community. The lessons
and recommendations herein may not be applicable to each and every situation.
Questions concerning this document or its application should be addressed to:
Paul Lemieux
National Homeland Security Research Center
Office of Research and Development
U.S. Environmental Protection Agency
Mail Code E343-06
Research Triangle Park, NC 27711
919-541-0962
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Best Practices for Management of Biocontaminated Waste
lie of Contents
Page
Disclaimers
Table of Contents
List of Acronyms and Abbreviations
Glossary
EXECUTIVE SUMMARY
1. INTRODUCTION
1.1 Purpose of the Best Practices
1.2 Why These Best Practices are Necessary
1.3 Approaches for Decontamination and How It Generates Waste
2. SCOPE OF THE BEST PRACTICES
2.1 Intended Audience
2.2 Description of the Biological Agents of Interest
2.3 Description of the EPA Outlined Scenario 10
2.3.1 Determination of Extent of Contamination 12
2.4 Phases of Response and Recovery Efforts 13
3. STATE AND FEDERAL BIOAGENT WASTE HANDLING PROCEDURES 15
3.1 Amerithrax Lessons Learned 16
3.2 Ricin Lessons Learned 17
3.3 Hurricane Katrina Lessons Learned 18
3.4 Ebola Virus Lessons Learned 19
3.5 Highly Pathogenic Avian Influenza Lessons Learned 19
4. PLANNING ASSUMPTIONS 21
4.1 Pre-lncident Management Planning 21
4.1.1 Available Management Tools 23
4.2 Nature and Consequences of a Biological Incident 24
4.3 Bioagent Waste Characterization 25
4.4 Estimated Types and Quantities of Waste 26
Estimated Types and Quantities of B. anthracis Waste 26
4.5 Worker Health and Safety 27
4.6 Health and Safety Training 28
4.6.1 PPE for Personnel 29
5. RESPONSE MANAGEMENT/AGENCY ROLES/RESPONSIBILITIES 31
5.1 Resource Personnel Needed from Response Management 32
6. BIOAGENT WASTE MANAGEMENT OPERATIONAL CONCEPTS 33
6.1 On-site Decontamination 34
6.2 Human Decontamination 34
6.3 Animal Decontamination 37
6.4 Premises Decontamination 38
6.5 Vehicle Decontamination 38
7 SOURCE REDUCTION, SEGREGATION, STAGING, AND PACKAGING, FOR
BIOCONTAMINATED WASTE 40
7.1 Waste Handling 40
7.2 Segregation and Source Reduction 41
7.3 Waste Staging 43
7.3.1 Waste Packaging and Tracking 44
Waste Packaging and Tracking for B. anthracis Incident 45
8 WASTEWATER COLLECTIOn/CONTAINMENT/STORAGE 47
8.1 Wastewater Treatment 47
8.2 Aerosol Containment from Wastewater 48
9 BIOWASTE SAMPLING 49
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Best Practices for Management of Biocontaminated Waste
10 TRANSPORTATION AND DISPOSAL 51
Transportation and Disposal for B. anthracis Incident 51
10.1 Handling/Offloading of Waste at Waste Management Facilities 52
11 CLEARANCE AND RE-OCCUPATION 55
Clearance for B. anthracis incident 55
12 CONCLUSION 56
13 REFERENCES 57
Appendix A: Development of the Pre-lncident WASTE MANAGEMENT Plan (WMP) A-2
Step 1: Pre-Planning Activities A-2
Step 2: Pre-lncident WMP A-2
Step 3: WMP Review, Maintenance, Exercise, and Training A-3
Step 4: Incident-Specific WMP A-3
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Best Practices for Management of Biocontaminated Waste
List of Figures
Page
Figure 1. Geospatial Concept of Operations (GeoCONOPS) Community Model 4
Figure 2. WARRP Biological Attack Scenario Description 12
Figure 3. Pre-incident All-Hazards Waste Management Planning Process 21
Figure 4. Pre-Incident Waste Management Planning Considerations 23
Figure 5. Example of incident command structure for biological incident 32
Figure 6. Contamination Site Standard Zone Designations 33
Figure 7. Waste Management Flow Chart for a Biological Incident 41
Figure 8. Packaging and Tracking Process for Sensitive Items for Off-site
Decontamination 44
List of Tables
Page
Table 1. Select Decontamination Technologies and Usage Conditions for B. anthracis-
contaminated Waste 8
Table 2. Characteristics for Tier 1 Select Agents 11
Table 3: Type/Number of Structures Impacted by WARRP Biological Incident Scenario 12
Table 4: Calculated Post-Decontamination Waste from WARRP Biological Scenario 13
Table 5: Key Preparation, Response, and Recovery Decisions 14
Table 6. Example Software Management Tools Available for Pre-lncident Planning 24
Table 8. Classification of Expected Waste Streams 27
Table 7. Personnel Training Requirements Overview 29
Table 8. Source Reduction Material Categories 42
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List of Acronyms and Abbreviations
ACM
Asbestos containing material
AHU
Air handling unit
APHIS
Animal and Plant Health Inspection Service
AVMA
American Veterinary Medical Association
IB IB IP
Bloodborne Pathogens
BOTE
Bioresponse Operational Testing and Evaluation
BROOM
Building Restoration Operations Optimization Model
C&D
Construction and demolition
CalElPA
California Environmental Protection Agency
CBIR
Chemical, Biological, Radiological
CBRN
Chemical, Biological, Radiological, and Nuclear
CDC
Centers for Disease Control and Prevention
CERCLA
Comprehensive Environmental Response, Compensation, and Liability Act
CIFR
Code of Federal Regulations
CI02
Chlorine dioxide
DeconST
Decontamination Strategy and Technology Selection Tool
DHS
U.S. Department of Homeland Security
DOHMH
Department of Health and Mental Hygiene
DOT
Department of Transportation
EPA
U.S. Environmental Protection Agency
ERLN
Environmental Response Laboratory Network
ESF
Emergency Support Function
EtO
Ethylene oxide
EVD
Ebola viral disease
FASTMap
Fast Analysis and Simulation Team Map
FIEIilA
Federal Emergency Management Agency
FFR
Filtering Facepiece Respirator
FIELDS
Fully Integrated Environmental Location Decision Support
FIFRA
Federal Insecticide, Fungicide, and Rodenticide Act
IFSIilA
Food Safety Modernization Act
GAQ
Government Accountability Office
GPS
Global Positioning System
h2o2
Hydrogen peroxide
HASP
Health and Safety Plan
HAZMAT
Hazardous Materials
HAZWOPER
Hazardous Waste Operations and Emergency Response
HI
High Efficiency Particulate Air
HHS
Health and Human Services
HMR
Hazardous Materials Regulation
HIPAII
Highly Pathogenic Avian Influenza
HVAC
Heating, Ventilation, and Air Conditioning
HW
Hazardous Waste
ICLN
Integrated Consortium of Laboratory Networks
ICS
Incident Command System
IC/UC
Incident Command/Unified Command
l-WASTE IDS'!
Incident Waste Decision Support Tool
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Best Practices for Management of Biocontaminated Waste
JIFO Joint Field Office
ILIRN Laboratory Response Network
MAA Mutual Aid Agreement
MSW Municipal Solid Waste
NASAAEP National Alliance of State Animal and Agricultural Emergency Programs
NAU Negative Air Unit
NOP National Contingency Plan
NGO Non-Governmental Organization
NIHSRC National Homeland Security Research Center
NIMS National Incident Management System
NIIGSH National Institute of Occupational Safety and Health
NISAC National Infrastructure Simulation and Analysis Center
NIRIF National Response Framework
QIRCIR Office of Resource Conservation and Recovery
ORNL Oakridge National Laboratory
OSHA Occupational Safety and Health Administration
P&DC Processing and Distribution Center
PAPR Powered Air-Purifying Respirator
WARE Prioritization Analysis Tool for All-Hazards/Analyzer for Wide Area Restoration Effectiveness
PCB Polychlorinated biphenyl
PIO Public Information Officer
PHMSA Pipeline and Hazardous Materials Safety Administration
PIN INI IL Pacific National Northwest Laboratory
POTW Publically Owned Treatment Works
PIPE Personal Protective Equipment
PSA Public Service Announcement
RCRA Resource Conservation and Recovery Act
SADA Spatial Analysis and Decision Assistance
SAM Standard Analytical Method
SCBA Self-Contained Breathing Apparatus
SIMIE Subject Matter Expert
TWG Technical Working Group
USAGE U.S. Army Corp of Engineers
USIDA U.S. Department of Agriculture
USPHS U.S. Public Health Service
VHP Vaporous Hydrogen Peroxide
VSP Visual Sample Planning
WAC Waste Acceptance Criteria
WARRP Wide Area Recovery and Resiliency Program
WEST Waste Estimation Support Tool
WERF Water Environment Research Foundation
WHO World Health Organization
WM Waste Management
WIMP Waste Management Plan
VI Wastewater Treatment Plant
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Best Practices for Management of Biocontaminated Waste
Glossary
All-Hazards - The spectrum of all types of hazards, including accidents, technological events, natural
disasters, terrorist attacks, warfare, and chemical, biological (including pandemic influenza), radiological,
nuclear, or explosive events.
Characterization - Facility or site sampling, monitoring, and analysis activities to determine the extent
and nature of the release. Characterization provides the basis for acquiring the necessary technical
information to develop, screen, analyze, and select appropriate cleanup techniques; characterization can
also provide the basis to estimate the volume of waste to be generated. This is distinct from Waste
Characterization (defined below), which is the process of determining whether a waste meets the
definition of hazardous waste under RCRA.
Code of Federal Regulations (CFR) - The codification of the federal regulations published in the
Federal Register by the executive departments and agencies of the federal government. Each volume of
the CFR is updated once each calendar year and is issued on a quarterly basis. See
http://www.ecfr.gov/cqi-bin/text-idx?tpl=%2Findex.tpl. Accessed July 5, 2016.
Incident - An occurrence caused by either human action or natural phenomena that may cause harm
and may require action. Incidents can include major disasters, emergencies, terrorist attacks, terrorist
threats, wild and urban fires, floods, spills of hazardous materials, nuclear accidents, aircraft accidents,
earthquakes, hurricanes, tornadoes, tropical storms, war-related disasters, public health and medical
emergencies, and other occurrences requiring an emergency response.
Hazardous Waste - For the purposes of these best practices, a solid or aqueous waste that may cause
an increase in mortality or serious illness or pose a substantial present or potential hazard to human
health or the environment when improperly treated, stored, transported, disposed of, or otherwise
managed. The Resource Conservation and Recovery Act (RCRA) governs hazardous waste
identification, classification, generation, management and disposal in title 40 CFR parts 260 through 273.
Pre-lncident Waste Management Plan - A plan that addresses the management of waste generated by
all hazards, particularly from homeland security incidents ranging from natural disasters and animal
disease outbreaks to chemical spills and nuclear incidents to terrorist attacks involving conventional,
chemical, radiological, or biological agents. Given the amount and types of waste that can be generated
during an incident, this plan is designed to assist emergency managers and planners in the public and
private sectors in preparing for the waste management needs associated with an incident, regardless of
the hazard. Experience has demonstrated that incident response would benefit from a pre-incident plan to
reduce or eliminate delays in the cleanup and recovery from the incident, as well as decreasing overall
costs.
Resource Conservation and Recovery Act (RCRA) - A 1976 federal law (42 U.S.C. §6901 et seq.) that
gives the EPA the authority to control hazardous waste from the "cradle-to-grave," including the
generation, transportation, treatment, storage, and disposal of hazardous waste. RCRA also set forth a
framework for the management of nonhazardous solid wastes. The 1986 amendments to RCRA enabled
EPA to address environmental problems that could result from underground tanks storing petroleum and
other hazardous substances.
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Safety Zone - Safety or work zones are established primarily to reduce the accidental spread of
biological substances by workers or equipment from contaminated areas to clean areas. Safety zones
specify the type of operation that will occur in each zone, the degree of hazard at different locations within
the release site, and the areas at the site that should be avoided by unauthorized or unprotected
employees.
Sharps waste - Sharps waste is a form of biomedical waste composed of used sharps, which includes
any device or object used to puncture or lacerate the skin. Sharps waste is classified as biohazardous
waste and must be carefully handled.
Staging Area - A temporary location at or near an incident site that is designated as a support or Cold
Zone used to stage personnel and equipment for immediate dispatch to the incident site to support
operations. There can be more than one staging area per incident.
Waste - Material in gaseous, liquid, or solid form for which no further use is foreseen.
Waste acceptance criteria - The terms "contaminated" and "uncontaminated" will be decided according
to the cleanup goals and waste acceptance criteria (WAC) of the disposal facilities.
Waste Characterization - This is distinct from general Characterization (defined above). Under 40 CFR
261.20-24, wastes can be designated as characteristic ("D" code) hazardous waste based on its
properties. A solid waste defined as hazardous because it exhibits one of the following four
characteristics: ignitability, corrosivity, reactivity, or toxicity as determined by the toxicity characteristic
leaching procedure (TCLP). Wastes that fail the TCLP are deemed hazardous wastes regardless of what
process generated the waste.
Waste Management - For the purposes of these best practices, the administration of activities that
include, but are not limited to, waste collection and characterization, waste segregation and minimization,
labeling and packaging, decontamination, recycling, transport, staging, storage, treatment, disposal and
tracking and reporting.
Waste Staging - Temporarily storing waste for the purpose of accumulation and sorting to facilitate
transportation, transfer, treatment and/or disposal, and to keep biological waste from contaminating non-
hazardous waste streams.
Waste Staging Area - A location at an incident site designated for the temporary accumulation and
sorting of biological waste and debris until that waste is manifested and shipped to an off-site disposal
facility.
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Best Practices for Management of Biocontaminated Waste
EXECUTIVE SUMMARY
This document was prepared to provide best practices on the fate and transport of waste management
operations after a biological agent incident, including best practices for handling waste after a biological
incident. Initially, an extensive literature review was conducted of waste management topics related to
types of biological and non-biological incidents such as natural disasters, operational exercises, medical
waste handling during a disease outbreak, and the cleanup of sites contaminated by the intentional
dissemination of a biological warfare agent. The review included the packaging and handling of biological
waste, sampling and analysis for waste classification and identification, worker training, best practices for
on-site waste treatment, waste disposal, personal protective equipment (PPE) selection and use, and
information on biological agents of interest. The literature review was limited to previously published
information from scholarly journals, the EPA, and other state and federal agencies, as well as
unpublished, institutional knowledge the EPA has gained during responses to biological agent
contamination. This document presents best practices for biocontaminated waste management that
incorporates the results from the literature review, but is not a literature review in and of itself. These best
practices also cite publicly available online guidance and handbooks that may be considered when
responding to a biological agent incident.
The purpose of these best practices is to provide federal, state, territorial, and local waste management
entities information on techniques and methodologies that have the potential to improve the handling and
management of biocontaminated waste streams after a biological agent incident. These best practices
are intended to be general in nature serving as a resource to a variety of biological agents in a variety of
situations; however, these best practices also present a specific homeland security scenario - a biological
attack with Bacillus anthracis - to help illustrate specific waste management considerations.
These best practices also discuss the importance of "pre-incident" waste management planning to
potentially improve waste management preparedness. Although waste management is typically viewed
as a function associated with later phases of the response and recovery, waste will start being generated
immediately after an initial contaminating incident; therefore, pre-incident waste management planning is
needed as well. It is not possible to pre-plan to a site-specific level, because the waste management
approach will depend on the location-specific situation at the time of an incident. However, by considering
waste management in advance, it becomes much easier to tailor a pre-incident waste management plan
(WMP) to a specific site or biological incident rather than waiting to develop a plan after the incident
occurs.
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Best Practices for Management of Biocontaminated Waste
1. JCTION
The U.S. Environmental Protection Agency (EPA) is designated as a coordinating agency under the
National Response Framework (NRF) Emergency Support Function (ESF) 10 to prepare for, respond to,
and recover from a threat to public health, welfare, or the environment caused by actual or potential oil
and hazardous materials incidents (Department of Homeland Security (DHS); 2008a). Hazardous
materials include chemical, biological, and radiological substances, whether accidentally or intentionally
released. This document focuses on waste management of biocontaminated waste streams - not the
releases themselves - except in some places where the best practices may vary depending on the
progression of the release. Emergency response to these biological releases is governed by a number of
Occupational Safety and Health Administration (OSHA) standards, including OSHA's Hazardous Waste
Operations and Emergency Response (HAZWOPER) Standard (29 CFR 1910.120 or 29 CFR 1926.65).
The 29 CFR 1910.120 standard applies to general industry and 29 CFR 1926.65 applies to the
construction, respectively.
The NRF provides guidance for response and initial recovery functions immediately following an incident
and consists of Incident Annexes that address the unique aspects of seven incident categories where
specific roles involving waste management occur. Of particular interest for this document is the Biological
Incident Annex that outlines biological incident response actions and procedures, and activities related to
recovery. EPA's role for this type of incident is to support the determination of the extent of the
contaminated area, sampling, and decontamination efforts (DHS, 2008b).
EPA is also designated as a support Agency for the U.S. Department of Agriculture's (USDA's) Animal
and Plant Health Inspection Service (APHIS) activities in agricultural emergency response. Section 208
(a) of the Food Safety Modernization Act (FSMA) states that the EPA Administrator, in coordination with
the U.S. Department of Health and Human Services (HHS), DHS, and USDA, shall provide support for,
and technical assistance to, state, local, and tribal governments in preparing for, assessing,
decontaminating, and recovering from an agriculture or food emergency. The NRF Food and Agriculture
Incident Annex describes the roles and responsibilities associated with all incidents involving the nation's
agriculture and food systems that require a coordinated federal response. EPA's role for this type of
incident is focused on decontamination and disposal efforts (DHS, 2008c).
EPA's National Homeland Security Research Center (NHSRC) provides expertise and products that can
be widely used to prevent, prepare for, and recover from public health and homeland security
emergencies arising from terrorist threats and incidents. To support this effort, this document was
prepared to provide best practices on the fate and transport of waste management operations after a
biological agent incident, including best practices for handling waste after a biological incident. Initially, an
extensive literature review was conducted of waste management topics related to types of biological and
non-biological incidents such as natural disasters, operational exercises, medical waste handling during a
disease outbreak, and the cleanup of sites contaminated by the intentional dissemination of a biological
warfare agent. The review included the packaging and handling of biological waste, sampling and
analysis for waste classification and identification, worker training, best practices for on-site waste
treatment, waste disposal, personal protective equipment (PPE) selection and use, and information on
biological agents of interest. The literature review was limited to previously published information from
scholarly journals, the EPA, and other state and federal agencies, as well as unpublished, institutional
knowledge the EPA has gained during responses to biological agent contamination. This document
presents best practices for biocontaminated waste management that incorporates the results from the
literature review, but is not a literature review in and of itself. These best practices also cite publicly
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Best Practices for Management of Biocontaminated Waste
available online guidance and handbooks that may be considered when responding to a biological agent
incident.
1.1 Purpose of the Best Practices
The purpose of these best practices is to provide federal, state, territorial, and local waste management
entities information on techniques and methodologies that have the potential to improve the handling and
management of biocontaminated waste streams after a biological agent incident. These best practices
are intended to be general in nature serving as a resource to a variety of biological agents in a variety of
situations; however, these best practices also present a specific homeland security scenario - a biological
attack with Bacillus anthracis (B. anthracis) - to help illustrate specific waste management considerations.
A summary of the types of biological agents these best practices are intended to cover is discussed in
Section 2.2.
When available, this best practices document will provide specific examples to a B. anthracis
attack. These specific examples will be designated by these graphic boxes.
For biological agent incidents (e.g., anthrax attack), it will be necessary to assess the extent of
contamination and decontaminate victims, responders, animals, equipment, transportation conveyances,
buildings, critical infrastructure, and large outdoor areas. Management of waste from a biological incident
is complicated by having no overall federal-level regulations that specifically address all aspects of such
waste. However, with or without an overall federal framework, states have the ability to establish more
stringent requirements than federal requirements. Analysis of the processes involved in managing waste
from biological contamination incidents has revealed that there are several potential routes of human
exposure to biological agents (including, but not limited to, inhalation, ingestion, skin contact, and sharps).
These exposures could happen during waste handling, treatment, sampling, packaging, transportation,
and disposal operations and should be avoided and/or minimized in terms of worker safety and public
health protection.
These best practices also discuss the importance of "pre-incident" waste management planning to
potentially improve waste management preparedness. Although waste management is typically viewed
as a function associated with later phases of the response and recovery, waste will start being generated
immediately after an initial contaminating incident; therefore, pre-incident waste management planning is
needed as well. It is not possible to pre-plan to a site-specific level, because the waste management
approach will depend on the location-specific situation at the time of an incident. However, by considering
waste management in advance, it becomes much easier to tailor a pre-incident waste management plan
(WMP) to a specific site or biological incident rather than waiting to develop a plan after the incident
occurs. Public communication should be considered when developing Pre-incident WMPs.
1.2 Why These Best Practices are Necessary
Currently, very few Pre-incident WMPs for biological agents exist; therefore, the best practices discussed
in this document can provide valuable assistance (see Section 4 and Appendix A) in the development of
new plans. Due to the infrequent nature of these types of incidents, there may be a lack of institutional
knowledge of best practices on how to deal with the wastes generated from such incidents in a practical
manner so that: 1) waste management activities do not adversely impact public health, worker safety, and
the environment; and 2) the impact that waste management activities have on the remediation timeline is
minimized so that affected areas and facilities can be safely brought back to re-occupancy and operation
as quickly as possible.
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During a biological incident with B. anthracis, the causative agent of anthrax, the magnitude and
complexity of the problem (indoors and outdoors, water and wastewater systems) and competing
interests (regulatory, economic, public safety) will challenge existing operational frameworks.
Preparing guidelines for response and recovery planning, specifically from a B. anthracis incident,
will reduce the expenditure of time and resources required to recover a wide urban area following
a biological incident, including meeting public health requirements and restoring critical
infrastructure, key resources (both civilian and military), and high-traffic areas.
In a biological incident, federal, state, tribal, territorial, and local officials require a highly coordinated
response to public health and medical emergencies. The incident may cross multiple jurisdictions,
requiring the simultaneous management of multiple incident sites in coordination with multiple state, tribal,
territorial, and local jurisdictions. These stakeholders may all play some type of role in preparing for,
assessing, decontaminating, and recovering from a biological incident. The Geospatial Concept of
Operations (GeoCONOPS) is an effort focused on supporting DHS and the emergency management
activities that are required to support the NRF, ESF, and supporting federal partners. The GeoCONOPS
is a community model that provides guidance on governance, policies, and processes as provided by
Presidential Policy Directive 8 (PPD-8) and key stakeholders (i.e., state authorities, public law authorities,
and their relationships). Figure 1 illustrates the GeoCONOPS Community Model that shows how the
geospatial community interacts to accomplish the homeland security and emergency mission.
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Best Practices for Management of Biocontaminated Waste
Stafford Act Public Law
State Authorities
Figure 1. Geospatial Concept of Operations (GeoCONOPS) Community Model
1.3 Approaches for Decontamination and How it Generates Waste
This document focuses on waste management of biocontaminated waste streams. To understand the
various issues related to managing and handling materials that make up a waste stream, it is important to
understand the approaches that can be taken to decontaminate the sites associated with biological agent
releases/events that may occur. The waste streams discussed in this best practices document are a
result of wide area and building decontamination methods described below. It should be emphasized that
no single decontamination technology or strategy is effective for every situation. Decontaminating an area
or item contaminated by a biological agent involves numerous issues specific to an individual location.
Regulatory requirements will guide decontamination activities, likely coordinated by the EPA, with input
from the CDC, under CERCLA regulations. Ultimate decisions will be those made at the scene by the
incident Command/Unified Command (IC/UC) (Raber et ai., 2011).
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Decontamination is a process that, when applied to contaminated materials, reduces the concentration of
microorganisms or biotoxins of concern to a level considered safe by an appropriate regulatory authority.
For a wide-area urban biological incident, the following seven categories of decontamination technologies
may be considered for contaminated outdoor areas, indoor facilities and their contents, and water
systems:
• Large-scale liquid distribution systems (such as firefighting or crop-dusting equipment) with
selected reagents or surfactants to decontaminate and stabilize outdoor surfaces.
• Liquid or semi-liquid reagents to decontaminate exposed nonporous and porous surfaces,
respectively, for indoor use as well as potential small-scale outdoor applications.
• Gaseous or vaporized reagents to decontaminate difficult-to-reach porous and nonporous indoor
surfaces, including HVAC or air handling unit (AHU) systems.
• Technologies to decontaminate sensitive or expensive electronic equipment.
• Technologies to decontaminate small, personal, or valuable items such as certain artwork.
• Approaches to treat/decontaminate and minimize solid waste or wastewater.
• Approaches to decontaminate water resources and drinking water systems.
Using B. anthracis as an example, select decontamination methods, their suitable usage conditions and
phase of use during the decontamination process (source reduction or treatment/decontamination), and
handling post-decontamination are outlined in Table 1. Once selected, decontamination processes are
monitored as they are carried out, followed by evaluation to determine whether the desired level of
contamination reduction has been achieved.
Methods to inactivate a biological agent include physical decontamination and chemical decontamination.
Physical decontamination uses heat or radiation or removes the agent from the area or surface (rinsing
with soap and water). Chemical decontamination involves the use of antimicrobial disinfectants or
sterilants. Currently, liquid peroxyacetic acid with hydrogen peroxide (Peridox with the Electrostatic
Decontamination System, EPA Registration Number 81073-2, Conditional), Steriplex Ultra™ (EPA
Registration Number 84545-11), and DIKLOR G Chlorine Dioxide Sterilant Precursor (EPA Registration
Number 73139-3) are the only chemical decontamination reagents registered by the EPA specifically for
inactivation of B. anthracis spores. Therefore, for each specific use of any other selected chemical
reagent to decontaminate a location contaminated by B. anthracis spores, a Federal Insecticide,
Fungicide, Rodenticide Act (FIFRA) exemption may need to be obtained from EPA for site- and incident-
specific use. In the past, the EPA approved eight chemicals for indoor use only against B. anthracis
spores, each to be used by authorized personnel following the specific requirements of its crisis
exemption:
• vaporous hydrogen peroxide (VHP),
• liquid and gaseous chlorine dioxide (CIO2) created from sodium chlorite or sodium chlorate,
• liquid sodium hypochlorite (bleach, diluted 1:9 with water and neutralized with vinegar to pH 7),
• solid paraformaldehyde (heated to create formaldehyde gas),
• gaseous methyl bromide,
• liquid peroxyacetic acid with hydrogen peroxide,
• liquid hydrogen peroxide, and
• gaseous ethylene oxide (EtO).
Although the liquid chemicals potentially could be effective outdoors, the IC/UC must consult with the
EPA about the need for obtaining approval for use of the unregistered antimicrobial chemical under a
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Best Practices for Management of Biocontaminated Waste
FIFRA exemption for each specific site. Fumigants such as methyl bromide, which is injected as a pre-
plant agricultural soil fumigant and contained with a plastic tarp, also could be considered for outdoor
(soil) uses. Decontamination methods that work solely through physical means, such as heat, rinsing,
cleaning, washing, or vacuuming, would not be subject to FIFRA and would not need a FIFRA exemption.
Similarly, decontamination of biotoxins may not require a FIFRA exemption because biotoxins are not
living organisms.
Liquid surface decontamination will generate decontamination waste that must be properly disposed of.
Physical treatment with wet or dry vacuuming will produce contaminated collection waste in the capture
vessel and/or filter that will require appropriate treatment and disposal. Treated surfaces should
subsequently be decontaminated, generating additional waste. Some technologies may involve
considerable post-decontamination cleaning of treated surfaces to neutralize the decontaminant and
process any waste generated (New York City DOHMH, 2015).
In general, for all but the HVAC systems, decontamination by normal porous surface methods such as a
thorough shampooing with a sporicidal agent of the carpets, seats, and other surfaces may be
satisfactory. If possible, assessments of the HVAC system for contamination should be conducted. If the
system is found to be contaminated, a portable fumigant generator, as well as other elementary
fumigation techniques such as formaldehyde, might be effective.
Gross decontamination of highly contaminated areas can be used to pre-treat (e.g., HEPA vacuuming,
surface decontamination) prior to the main decontamination event to improve the efficacy of the
decontamination and minimize re-aerosolization. Treated waste cannot be considered to be
uncontaminated solid waste unless waste sampling results verify that the established waste acceptance
criteria (WAC) have been met. In general, on site (in situ) processes are preferable because they avoid
the need to package and transport large quantities of contaminated waste to an on- or off-site waste
management site or facility. In addition, if materials that enter the waste stream have been
decontaminated in situ with the rest of the building, then waste handling might be able to be performed
using lower levels of PPE. Off-site waste treatment requires identification of a treatment facility willing to
accept the waste, the size of the load to be treated, the variety of waste streams, the need for waste
segregation, pre-treatment requirements, and the type of packaging needed to contain the waste.
Deciding which decontamination method to apply at a given location requires in-depth evaluation of
available methods, including the following factors:
• Availability and capacity of specific decontamination technologies;
• Emergency-response plans to address potential uncontrolled reagent release;
• Safety (e.g., toxicity, byproducts, persistence, and exposure limits);
• Efficacy (e.g., required contact times, penetration capability, efficacy data, and history of use);
• Generation, distribution, monitoring, and removal requirements;
• Cost (e.g., materials, equipment, and labor);
• Time (e.g., procurement, setup, testing, decontamination, removing equipment);
• Stakeholder concerns, including site- and incident-specific considerations;
• Waste generation; and
• Materials compatibility (DHS and EPA, 2009; Raber et al., 2011).
Site-specific environmental factors can play a significant role in the ability to achieve and maintain certain
target decontamination application conditions (EPA, 2015). For example, low humidity, high
temperatures, and wind can help dry materials during the application of liquid decontaminants but may
also require increases in liquid volume applied, increasing the number of reapplications if the materials
are to remain wet for certain target times. Similarly, achieving the appropriate temperature and humidity in
6
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Best Practices for Management of Biocontaminated Waste
cold or arid environments may be challenging for certain fumigants with such requirements. Fumigants
used to decontaminate a building or other type of contaminated area may require containment for safety
reasons as well as to reduce the quantity of gas needed to maintain the target conditions. Following
fumigation, activated carbon units may be used as an air scrubber to vent the decontaminated area,
depending on the fumigant used. In addition, HEPA filters may be used during aeration as a precaution to
capture spores prior to clearance confirmation. If liquid chemicals are used for decontamination, surface
runoff may require collection and treatment before disposal or release into the environment. The type and
quantity of decontaminant and the method of disposal (such as release into a sanitary or storm sewer
system, if acceptable to local authorities, or management as a hazardous waste) will determine the level
of treatment required. Local water and sewer authorities should be contacted to determine the
acceptability of plans to allow decontaminant runoff to enter natural waterways or discharge into sewer
systems.
The type of decontamination method(s) employed will also impact the total quantity of liquid and solid
waste generated. An EPA field-study was conducted to examine the effectiveness of three
decontamination methods, separately, against B. anthracis spores in laboratory and/or field use (EPA,
2013). The methods tested were: 1) fumigation with hydrogen peroxide (H2O2), 2) a decontamination
process incorporating the spraying of surfaces with pH-adjusted (or amended) bleach, and 3) fumigation
with CIO2 gas. For the particular scenario investigated in the field study (other scenarios may produce
different results), results determined that the largest amount of solid waste was generated during the pH-
adjusted bleach decontamination process in which porous surfaces were removed, bagged,
decontaminated off site, and treated as waste (EPA, 2013). Waste generated during fumigation with VHP
and CIO2 only included items such as PPE and sampling waste (e.g., packaging) for both building
decontamination and sampling. The largest amount of liquid waste was also generated during the pH-
adjusted bleach decontamination process resulting from decontamination of the building.
Decontamination liquid waste, comprised of the rinsate (a mixture diluted by water, solvents, oils, or
rinsing agents or any other substances) recovered from the decontamination line, was also generated
from all three methods during sampling.
7
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Best Practices for Management of Biocontaminated Waste
Table 1. Select Decontamination Technologies and Usage Conditions for B. a/7f/7/-ac/5-contaminated Waste.
Decontamination Technology
General Usage Conditions
r. .. Sensitive
Porous Nonporous ..
r Items
Off site Source
Treatment Reduction
Phase for Use
>urce _ . .
.. Treatment
Post Decontamination Waste Handling Procedures
Physical
HEPA Vacuuming
X
X
X
Surfaces will require subsequent decontamination; contaminated HEPA
filters must be safely disposed
Liquid
Sodium Hypochlorite
solutions (bleach)
X
X
X
X
Item disposed as treated waste upon agent sampling verification
The bleach solution should be pH neutralized before disposal
Hydrogen peroxide and
Peroxyacetic Acid
X
X
X
Item disposed as treated waste upon agent sampling verification
Fumigation
CIO2
X
X
X
Item disposed as treated waste upon agent sampling verification
Area re-entry, as applicable, following agent sampling verification and
demonstration of absence of fumigation residues. Residual gaseous
material could be entrained in a wastewater stream and disposed of as
liquid waste. Facilities must remain closed until both decontamination of
the biological agent and the complete removal of the CIO2 have been
demonstrated.
EtO
X
X
X
Item disposed as treated waste upon agent sampling verification
Due to the explosive nature of EtO, these Systems are typically capable
of treating small surface volumes (i.e., sensitive items that will allow
reuse). Alternatively, the treated sensitive items could be reused;
otherwise if the sensitive item is too large then paraformaldehyde, VHP,
or CIO2 can be used and the item should be disposed.
Methyl bromide
X
X
X
X
Area re-entry, as applicable, following agent sampling verification and
demonstration of absence of fumigation residues.
Paraformaldehyde
X
X
X
X
Item disposed as treated waste upon agent sampling verification
Area re-entry, as applicable, following agent sampling verification and
demonstration of absence of fumigation residues. Due to the suspected
carcinogenic and toxic nature of paraformaldehyde, any building treated
with paraformaldehyde must have formaldehyde gas neutralized with
ammonium bicarbonate and be properly ventilated, or have a specially
designed ventilation system.
VHP
X
X
X
X
X
Item disposed as treated waste upon agent sampling verification
Area re-entry, as applicable, following agent sampling verification and
demonstration of absence of fumigation residues.
Steam and
Pressure
Autoclave
X
X
X
X
Item disposed as treated waste upon agent sampling verification
Thermal
Incineration
X
X
X
X
Item disposed as treated waste upon agent sampling verification
Ionizing
Irradiation
Irradiation
X
X
X
Item disposed as treated waste upon agent sampling verification
8
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Best Practices for Management of Biocontaminated Waste
2. v.'Mi |„ Ml- 1HEIR vl t I¦ rV 1'K II .
This document aims to provide best practices for waste management activities, including waste handling,
treatment, sampling, packaging, transportation, and disposal operations for waste that potentially contains
biological agents, including information and proposed best practices for maximizing the efficiency of
waste management operations while minimizing potential exposure of workers, as well as protecting
public health and the environment. To set up a context for the situation under which this SOG might prove
useful, a hypothetical biological contamination incident scenario will be presented in Section 2.3.
2.1 Intended Audience
The target audience for this SOG consists of those involved with the decision-making process for waste
management activities prior to and during a biological incident response, including federal, state, and
local emergency planners and managers who are tasked with developing Pre-lncident WMPs under the
National Contingency Plan (NCP) and the National Planning Frameworks; the IC/UC; and the Technical
Working Group (TWG) that may convene under the IC/UC. Other potential audiences might include
members of the environmental group developing WMPs, the Planning Section Chief and Operations
Section Chief in the IC response structure, workers who perform the waste handling and their employers,
and waste treatment/disposal facilities that process the waste. More information about agency roles and
responsibilities during a response can be found in Section 5.
scription of the Biological Agents of I interest
The main groups of biological agents of human interest are as follows:
• Bacteria: Most species are capable of reproducing outside living cells. Microscopic cells range in
size from approximately 1 to 2 microns in diameter to approximately 2 to 10 microns in length
(1,000 microns = 1 millimeter). Some bacterial diseases may respond to treatment with
antibiotics. Vaccines are available for some bacterial diseases. Some species of bacteria such as
B. anthracis are able to form endospores when unfavorable conditions are encountered (e.g.,
nutrient depletion). In this dormant spore state, these bacteria are more resistant to adverse
condtions such as extreme heat or dryness than when in their non-dormant vegetative state.
Once conditions are favorable, the spores can revert to their replicating vegetative state. When
growing these types of bacteria in the laboratory, it is possible to induce them to form endospores
under certain conditions.
• Viruses: Viruses cannot replicate outside living cells and require a living host to replicate. Viruses
are typically much smaller in size than most bacteria (ranging from 0.02 to 0.2 microns). Viruses
do respond to the correct antiviral treatment, but the correct one for a particular virus may not be
known or tested. Vaccines are available for some viral diseases (e.g., measles).
• Biological toxins fbiotoxins): Toxic substances produced by or extracted from bacteria, fungi,
plants, or animals. Toxic substances can also be synthesized in the laboratory. Toxins do not
replicate and are not contagious. Biotoxins are categorized into groups according to their
molecular weight and composition or origin.
Biological agents are generally characterized by their infectivity/toxicity, lethality, severity of disease
(virulence), mechanism of transmission, and stability. (Most bacterial and viral diseases are not
contagious in humans, meaning they are are not transmissable directly from person to person (e.g., B.
anthracis), whereas diseases caused by some agents can be transmitted (Yersinia pestis). Biological
9
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Best Practices for Management of Biocontaminated Waste
toxins are not contagious. These characteristics, among others (e.g., availability, ease of production) can
contribute to interest in an agent for use in a deliberate biological attack.
The HHS and the USDA have published lists of microorganisms and biological toxins that are part of the
Federal Select Agent Program regulated by the Centers for Disease Control and Prevention (CDC) and/or
USDA's APHIS, depending on the agent category (refer to 7 CFR Part 331, 9 CFR Part 121, 42 CFR Part
73). The agents have been determined to have the potential to pose a severe threat to both human and
animal health, to plant health, or to animal and plant products. Three categories have been defined
regarding select agent and toxin identification: HHS select agents and toxins, Overlap select agents and
toxins, and USDA select agents and toxins. Those classified as HHS agents have the potential to pose a
severe threat to public health and safety. Overlap select agents and toxins have the potential to pose a
severe threat to public health and safety and also to animal health or to animal products. USDA select
agents and toxins have the potential to pose a severe threat to public health and safety, to animal or plant
health, or to animal or plant products. A subset of the agents on the Select Agents and Toxins List are
designated as "Tier 1" agents since they "present the greatest risk of deliberate misuse with significant
potential for mass casualties or devastating effect to the economy, critical infrastructure, or public
confidence, and pose a severe threat to public health and safety" (CDC, 2014). Key characteristics of the
HHS and Overlap Tier 1 Select Agents and Toxins are outlined in Table 2.
/\
Not all biological agents potentially encountered or found in environmental contamination are
listed in the select agents list in Table 2; however, the best practices in this document may be
applicable to them.
V w
2.3 Description of the EPA Outlined Scenario
The agent used in the outlined scenario in this document is B. anthracis. The hypothetical biological
incident scenario is consistent with National Planning Scenario 2 and was developed as part of the Wide
Area Recovery & Resiliency Program (WARRP) in 2011 (DHS, 2012). This program worked with
interagency partners (including federal/state/local/tribal governments), the military, private industry, and
non-profit organizations to develop solutions to reduce the time and resources required to recover wide
urban areas, military installations, and other critical infrastructure following a catastrophic Chemical,
Biological, or Radiological (CBR) incident. The biological agent selected for the scenario was B.
anthracis. The scenario, tailored for the urban Denver, Colorado area, consisted of a hypothetical covert
attack by an organized worldwide terrorist group. The attack resulted in tens of thousands of people being
exposed. A fraction of exposures resulted in deaths; a large number of exposures resulted in illness of
varying levels of severity, thereby challenging medical facilities and personnel and requiring a significant
amount of logistical coordination.
In general, an attack involving B. anthracis represents a difficult, long-term remediation problem
because: 1) the agent is considered the most difficult of known potential biological agents to
decontaminate, 2) B. anthracis spores remain viable for lengthy periods, and 3) dried spores are
able to re-aerosolize in both indoor and outdoor environments (Raber et al., 2011).
The areas significantly impacted by the contamination included critical infrastructure and commercial,
military, and private property, covering over two areas of 10 square miles each and resulting in 500
contaminated buildings. The contamination caused local government operations to be relocated, and
basic services, local businesses, and military installations were affected. A detailed description of the
scenario is presented in Figure 2.
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Best Practices for Management of Biocontaminated Waste
Table 2. Characteristics for Tier 1 Select Agents.
Agent3'
Key Characteristics
Disease
Type
Incubation Period
Contagious?
Relative Stability/
Persistence
Infectivity/Toxicity
and or Lethality
Prophylaxis /
Treatment
Clostridium
botulinum
neurotoxins
Botulism
Biotoxin
6 hours to 10 within
12 to 36 days,
often hours
No
Readily inactivated by
sunlight and air; heating to
80 °C (176 °F) destroys
botulism toxin; heating to
more than 100 °C (212 °F)
destroys Closthdium
botulinum spores
Lethality 50 to 60%
without treatment; 5 to
10% with treatment
None/Various
antitoxins
Ebola virus
Ebola
Virus
2 to 21 days
Yes
Low
Case fatality rate is
approximately 50%
In development/In
development
HHS
Agents
and
Toxins
Francisella
tularensis
Tularemia
Bacteria
3 to 14 days
No
Less than one day if
aerosolized; can persist for
weeks in soil and water
Lethality approximately
1.4 %, higher for
pneumonic form
None/Antibiotics
Variola major
virus
Smallpox
Virus
7 to 17 days
Yes
Destroyed by sunlight and
heat; virus dies within 24
hours if aerosolized; more
persistent in colder
temperatures
Lethality approximately
30%
Vaccine/None
Yersinia
pestis
Bubonic
plague
Bacteria
Two to six days for
bubonic; one to six
days for pneumonic
Yes
Readily inactivated by
sunlight; Y. pestis can
survive in soil up to 3.5
months (more than 10
months in colder climates),
in tap water up to 16 days,
and in sterilized bottled
water up to two years
High for pneumonic if
untreated/lethality about
11%
None/Antibiotics
Bacillus
anthracis
Anthrax
Bacteria
One to seven days;
pneumonic cases
have occurred 60
days after
exposure
No
Spores highly
persistent/stable; risk of
secondary aerosolization
Moderate/high for
inhalation exposure if
not quickly diagnosed
Vaccine/Antibiotics
Overlap
Agents
Burkholderia
mallei/
pseudomallei
Glanders /
Melioidosis
Bacteria
One day to four
weeks for B, mallei;
one to 21 days for
B, pseudomallei,
although may be
months or years
Rare
B. mallei can survive in
water up to 30 days; B,
pseudomallei can survive in
water over three years and
in moist soil for u p to two
years
Animal infectivity high
for both; human
infectivity rare for B.
mallei but common for
B. pseudomallei/
lethality can be as high
as 50% for both, even
with treatment
None/Antibiotics
a Marburg virus which has characteristics similar to Ebola virus and the milder form of smallpox virus,Variola minor virus (Alastrim), are also considered Tier 1 agents.
b Ebola (Ebola Virus Disease). Signs and Symptoms. Last accessed August 31, 2016: http://www.cdc.gov/vhf/ebola/symptoms/index.html
Source: Information derived from: (EPA, 2015), (CDC, 2014)
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Best Practices for Management of Biocontaminated Waste
WARRP Biological Attack Scenario
On an autumn Monday morning, a specialty fitted tractor trailer
turns onto a busy street and enters the late rush hour traffic that
is exiting downtown Denver. As the truck drives north, the driver's
companion turns on a concealed improvised spraying device with
a conventional nozzle that rapidly aerosolizes approximately 100
liters of wet fill B. anthracis (anthrax) slurry, 109 colony forming
units per milliliter (cfu/mL). The dissemination efficiency
achieved in the operation (1%) is comparatively modest.
Nonetheless, it is sufficient to result in the potential exposure of
330,000 persons. Denver area BioWatch samplers detect the
presence of anthrax. It is determined that the detected levels
have triggered a BioWatch Actionable Results finding, and it is
decided that a bioterrorism event has occurred. The appropriate
notifications are made. Source: (EPA, 2012)
Figure 2. WARRP Biological Attack Scenario Description.
2.3.1 Determination of Extent of Contamination
Based ori this scenario, the types arid number of structures impacted by the plume are summarized in
Table 3. Using the information presented in the scenario, the quantity of the waste generated was
estimated using EPA-developed tools and data designed to assist in the planning for wide-area
remediation activities, including:
• Waste Estimation Support Tool (WEST) (building stock and outdoor areas)
• Incident Waste Decision Support Tool (l-WASTE DST) (building contents)
• Bioresponse Operational Testing and Evaluation (BOTE) Personnel Decontamination Waste
Generation (EPA, 2013)
Table 3: Type/Number of Structures Impacted by WARRP Biological Incident Scenario.
Structure
Total Number
Fire Stations
4
Medical Facilities
8
Police Stations
11
Schools
78
Hazardous Materials Facilities
69
Residences
55,791
Everything Else
54,252
Source: (EPA, 2012)
Table 4 summarizes the calculated quantity of volumetric (liquid waste, expressed in gallons) and surface
(solid waste, expressed in tons) waste generated by emergency personnel following decontamination
based on the number of structures impacted by the scenario outlined in Table 3. Materials undergoing
decontamination include structural (brick wood, reinforced concrete, steel, etc.) and interior (ceiling tiles,
carpet, furniture, paper/office supplies, food, electronic equipment, etc.) contents.
12
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Best Practices for Management of Biocontaminated Waste
Table 4: Calculated Post-Decontamination Waste from WARRP Biological Scenario.
Waste Type
Post Decontamination Waste Quantity,
Total (based on Number of Structures)
Volumetric
Surface
Liquid Waste from Personnel
Decontamination During Sampling
(gal)
9,836,507
9,836,507
Liquid Waste from Personnel
Decontamination During
Decontamination (gal)
11,178,759
38,400,961
Total Liquid (gal)
21,015,266
48,237,467
I
Decontamination Waste from all
interior materials (tons)
11,389,009
33,545,017
Solid Waste from Personnel
Decontamination During Sampling
(tons)
13,367
13,367
Solid Waste from Personnel
Decontamination During
Decontamination (tons)
11,925
40,963
Total Solid (tons)
11,414,301
33,599,347
Source: (EPA, 2012)
2.4 Phases of Response and Recovery Efforts
When responding to a biological incident, effective and timely decision-making requires an understanding
of many aspects of response and recovery. The main phases and activities in preparing for and
responding to a biological incident are summarized in Table 5.
The preparation phase should commence prior to a biological incident. This phase should involve
planning, organizing, training, conducting exercises, evaluating, and improving procedures. The respond
and recover phases then commence, following an incident and encompasses two major parts: 1) crisis
management, and 2) consequence management. The primary activities in crisis management involve
notification and first response; however, because these best practices focus on waste management
activities that are primarily conducted in the consequence management phase, activities part of crisis
management will not be discussed further in this document. The consequence management phase
begins with characterization activities, which entail strategies to characterize the agent and the affected
site(s) and to examine the relative persistence and spread of the agent. This information is used to
assess the potential health and environmental consequences. As part of consequence management,
remediation activities then follow, focusing on implementation of plans to decontaminate the
contaminated site and its contents. Waste handling and waste management operations are implemented
in this phase. During the clearance stage, environmental sampling and analysis procedures are
performed to determine the effectiveness of the decontamination. The final clearance decision is made by
the IC/UC and/or responsible local/state agencies (e.g., public health). The consequence management
phase ends with restoration, which focuses on preparing an area or facility for re-occupancy, reuse, or
refurbishment. Prior to opening a site to the general public, decontamination must be deemed successful
(i.e., no significant risk exists). Additionally, longer-term environmental health monitoring may be required
to ensure that the re-occupancy and reuse criteria are met.
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Best Practices for Management of Biocontaminated Waste
Table 5: Key Preparation, Response, and Recovery Decisions.
Crisis Management
Pre-lncident
WMP
Incident-
Specific WMP
Organize, train,
and equip
Exercise
Evaluate and
improve
Develop SOG
documents
First
Notification
Response
Initiate first
Operational
response
Coordination Law
activities,
enforcement,
including
intelligence, and
notification of
investigative
proper authorities
response
Develop a public-
When and how to
engagement
distribute medical
campaign
countermeasures
Evaluate Threat
Recommend
Credibility
staying-in-place
or evacuation
Recommend
quarantine/
isolation/social
distancing
Implement
transportation
restrictions
Provide safety
and health
guidance and
protections to
impacted first
responders and
citizens
Issue guidance
on personal
hygiene or
decontamination
Provide support
for mass casualty
Establish mass
medical
treatment
facilities
Implement
modified
standards of care
Response and Recovery Phases
Consequence Management
Characterization Remediation Clearance
Develop/implement
strategies for
characterization in
facilities and the
outdoors
Implement strategies
and procedures to
identify, stabilize, and
maintain
infrastructure and
property
Determine
requirements and
methods to protect
natural and cultural
resources
Implement strategies
and means to contain
and mitigate the
spread of
contamination and
eliminate sources of
further distribution
Decontaminate
outdoor areas
and/or buildings
Decontaminate
wide areas
Implement
required
capabilities for
sustained
environmental
decontamination
operations
Implement
decontamination
waste handling
requirements
Worker health
and safety
Decontaminate
critical
infrastructure
Waste
management
Provide
guidance for
determination of
effectiveness of
decontamination
Restoration
Provide guidance
for re-occupancy
and reuse criteria
and goals
Provide guidance
for controls to
implement,
reduce, mitigate
any potential
exposures or
future incidents
after re-
occupancy
Implement public
messaging to
instill confidence
in the public and
workforce that re-
occupancy is
safe
Implement
measures to
retain, maintain
and improve the
economic vitality
of a region
Implement long
term health
treatment,
intervention and
surveillance
strategy
Source: Adapted from National Science and Technology Council (NSTC) Roadmap, 2013
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Best Practices for Management of Biocontaminated Waste
3. IDLING
PROCEDUF
Previous incidents that have occurred in the United States and generated large amounts of hazardous
waste requiring treatment and disposal can serve as case studies for identifying issues and solutions for
handling and managing biological agent-contaminated waste. This information is important for timely and
efficient planning and response to incidents.
As stressed in earlier sections, pre-incident waste management planning is needed. It is not possible to
pre-plan to a site-specific level, because the waste management approach will depend on the location-
specific situation at the time of an incident. This has also been a common occurrence in large incidents
involving biological/infectious agents (described below), or even manmade incidents such as the
Deepwater Horizon Oil Spill. It is not enough to have a plan; the plan should be exercised and trained
against to determine the success of the plan. Lessons learned from the exercises and training should be
captured and incorporated back into the plans to maintain constant improvement. There are multiple
examples (e.g., Amerithrax, Ebola Virus, Hurricane Sandy, Deepwater Horizon, Fukushima, etc.) where
existing debris/WMPs were not robust enough to address the incident. This is one of the reasons that
DHS has encouraged federal, state and local emergency planners and managers to utilize the National
Planning Scenarios in their planning. These scenarios require robust planning by having wide area
incidents that drive the need for thorough and well thought out plans.
A brief summary of the events and cursory review of lessons learned from several historical biological
incidents in the United States are discussed in the following sub-sections. The incidents reviewed
represent multiple classes of biological agents, including a spore-forming bacterium, two viruses, and a
biotoxin, as well as general waste debris.
• Amerithrax (2001); B. anthracis sent through the mail, contaminating mail facilities, media
buildings, and U.S. Senate facilities;
• Ricin biotoxin (2004); Ricin powder found in the Dirksen Senate Office Building in Washington,
D.C;
• Hurricane Katrina (2005); A Category 5 hurricane made landfall in New Orleans, Louisiana, as a
Category 4 hurricane, resulting in widespread devastation;
• Ebola Virus (2014); An outbreak of Ebola virus in West Africa resulted in several cases in the
United States;
• Highly Pathogenic Avian Influenza (HPAI) (2015); A multi-state outbreak of HPAI resulted in
many contaminated premises and millions of dead birds requiring disposal.
The lessons learned in these case studies are often broader than waste management issues; however,
by understanding all issues from a biological incident response, planners and responders may develop a
greater understanding of how to apply specific waste management best practices in a variety of
situations. From all of these incidents, a common lesson learned is that response planning should focus
on the Pre-lncident WMP first; by considering waste management in advance, it becomes much easier to
tailor a pre-incident WMP to a specific site or biological incident, which could prevent problems before an
actual incident occurs. Many of the lessons learned in these incidents occurred during the incident and
proved costly and difficult to implement.
15
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Best Practices for Management of Biocontaminated Waste
' t tn tithrax Lesson [ .irinecl
Three incidents of B. anthracis occurred in the United States in September of 2001. In the first release,
letters containing anthrax spores were mailed from New Jersey to media offices in New York City; the
letters passed through the Hamilton Processing and Distribution Center (P&DC) in Trenton, New Jersey,
on September 18. The second release involved a letter sent in late September to American Media
Incorporated in Boca Raton, Florida. In the third release, letters addressed to Senators Tom Daschle and
Patrick Leahy in the Hart Senate Office Building entered the Hamilton P&DC on October 9. Numerous
sites, including the Hart Senate Office Building, postal facilities, media offices, and residences, were
contaminated directly or through secondary contamination. The contaminated postal facilities included
physically large P&DCs such as the Hamilton P&DC and the Morgan P&DC in New York City (which
processes all mail into and out of Manhattan), and the Curseen-Morris facility (which handles all mail to
and from the federal government in the D.C. metropolitan area). Numerous smaller postal facilities also
were contaminated, as were a number of federal government mail facilities downstream of the Curseen-
Morris facility (Simpson 2005). Overall, approximately 3,250 bags of critical items and 4,000 packages
and drums of additional mail were sent for treatment (Government Accountability Office (GAO); 2003).
The Capitol Hill anthrax cleanup site included 26 buildings; samples from seven of the 26 buildings tested
positive for B. anthracis, which subsequently required further sampling followed by decontamination
(GAO, 2003).
Summary observations, recommendations and/or information gaps stemming from the incident response,
as identified from a cursory review of the literature, are captured below.
• Governmental entities should develop more extensive plans and procedures to maximize
involvement of all stakeholders; conduct further training and drills, especially for sampling,
analysis, and coordination procedures (Simpson, 2005).
• Determine the appropriate number, size, and locations of chlorine dioxide generators (Simpson,
2005).
• Following a wide-area attack, no materials, other than items that are essential or of high value or
may consume the decontamination reagent, should be removed from contaminated facilities
before decontamination because costs would otherwise be prohibitive: space and waste
management options are expected to be limited, and time is of the essence (Raberet al., 2011).
• A waste management plan should be developed at the same time as decontamination planning, if
not before. The waste management plan should reflect any state, local, or facility requirements
(e.g., decontamination actions, post-decontamination sampling, and PPE for transportation and
disposal facility workers) for the management of decontaminated material as municipal waste
(Raber et al., 2011).
• State authorities have the primary responsibility to regulate and oversee management of wastes
that may be contaminated with an infectious agent such as B. anthracis. It is highly advisable to
establish contact in advance of an incident or early in the remediation process with waste
management stakeholders such as publicly-owned wastewater treatment operators and landfill,
incinerator, and sterilization facilities (Raber et al. 2011).
• Determining ownership of items in a contaminated facility, such as valuable documents, remains
an issue. Owners and managers of these facilities should create and maintain ownership records
of valuable and important items; they should have detailed and current floor plans and information
about airflow patterns, under routine and non-routine conditions (Simpson, 2005).
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Best Practices for Management of Biocontaminated Waste
• To date, EPA has concluded that chlorine dioxide gas shows the most promise for remediating
contaminated facilities (Simpson, 2005); however, other solutions have been identified and are
available.
" 1-1 ;ni IE »soi i IE irned
Ricin is a biotoxin that can be extracted from castor beans relatively easily; many open-source literature
protocols exist for ricin isolation, and castor beans are readily accessible. Human exposure to ricin can
occur through several routes, including inhalation, ingestion, absorption, and injection. The most lethal
route of exposure is through injection, but exposure to ricin powder by other routes poses the most
serious public health and medical threat (HHS, 2006). Exposure to ricin in high doses can cause organ
failure and death, with initial symptoms developing within 4 to 8 hours of inhalation and within up to 10
hours for ingestion. In February 2004, white powder found in the Dirksen Senate Office Building in
Washington, D.C., tested positive for ricin and ricin white powder (HHS, 2006). Worldwide, incidents
involving criminal usage of ricin have occurred or are uncovered by law enforcement on an annual basis
since the late 1990s.
There are a number of OSHA standards that may apply to exposure to ricin, including the HAZWOPER
standard (29 CFR 1910.120 or 29 CFR 1926.65) during an environmental release or substantial threat of
a release, as well as the PPE standards (29 CFR 1910 Subpart I) in some exposure scenarios. Since
airborne particles may pose the greatest threat to personnel, respiratory protection is a necessary
component of the PPE program. Cleanup workers in situations requiring respiratory protection are
protected under the OSHA Respiratory Protection Standard (29 CFR 1910.134), which requires medical
clearance, Attesting, training, and other elements of a respiratory protection program beyond just
provision of respirators.
Summary observations, recommendations, and/or information gaps stemming from the incident response,
as identified from a cursory review of the literature, are captured below (HHS, 2006).
• It is important that first responders work in conjunction with law enforcement officials, as collected
samples of ricin may become evidence in a criminal prosecution. Law enforcement officials need
to be consulted before beginning decontamination activities to determine whether additional
evidence may exist at the crime scene.
• A high efficiency particulate vacuum may be used to reduce surface contaminant levels, the
spread of particulates, and the potential for re-aerosolization.
• Heating, ventilation, and air conditioning (HVAC) ducts serving the affected area may also need
to be sealed. The ducts can be sealed within the affected room or at external locations as long as
the selected decontamination technology effectively decontaminates the ductwork between the
room and the external seal. An HVAC specialist should be consulted.
• No decontamination wastewater should be discharged until the water is treated in accordance
with appropriate guidelines and until agreements have been reached with, and approved by, the
local utility manager, publicly owned treatment works operator, public health officials, and/or other
affected parties.
• With regard to sample packaging, guidelines should be followed to preserve the integrity of the
sample (i.e., prevent leakage), to clearly document what form the sample is in and where it was
collected, and to withstand possible rough handling during transport.
• The primary means of disposal for ricin-containing waste is through high-temperature thermal
incineration or through landfilling in a lined landfill. It is important to contact potential waste
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Best Practices for Management of Biocontaminated Waste
disposal facilities early on in the response, so that appropriate arrangements can be made and
potential regulatory and technical obstacles can be identified.
• Standards for re-occupancy of a building after a ricin event need to be developed.
3.3 Hurricane Katrina Itessoi tinned
On August 23, 2005, Hurricane Katrina formed as a tropical storm off the coast of the Bahamas. Over the
next seven days, the tropical storm grew into a catastrophic (i.e., category 3) hurricane that made landfall
first in Florida and then along the Gulf Coast in Mississippi, Louisiana, and Alabama, leaving a trail of
devastation and human suffering. Katrina wrought staggering physical destruction along its path, flooded
the historic city of New Orleans, ultimately killed over 1,300 people, and became the most destructive
natural disaster in American history (United States. Executive Office of the President and Assistant to the
President for Homeland Security and Counterterrorism, 2006).
Hurricane Katrina and the subsequent sustained flooding of New Orleans exposed significant flaws in
federal, state, and local preparedness for catastrophic events and the nation's capacity to respond to
them. Emergency plans at all levels of government were put to the test.
Overall, the major lesson learned, for the purpose of this document, was that there was no debris
management plan in place. As a result, the approach has changed in that DHS and the Federal
Emergency Management Agency (FEMA) have been encouraging an "all hazards" approach to planning.
Summary observations, recommendations, and/or information gaps stemming from the incident response,
as identified from a cursory review of the literature, are captured below.
• Federal response should better integrate the contributions of volunteers and non-governmental
organizations (NGOs) into the broader national effort. This integration would be best achieved at
the state and local levels, prior to future incidents. In particular, state and local governments must
engage NGOs in the planning process, credential their personnel, and provide them the
necessary resource support for their involvement in a joint response (United States. Executive
Office of the President and Assistant to the President for Homeland Security and
Counterterrorism, 2006).
• Physical work (e.g., removal of debris) generally is done by contractors, to the extent that it
cannot be accomplished by local government sanitation workers. FEMA reimbursed local
governments for debris removal on public and private property in counties that applied for
assistance (Esworthy et al., 2005).
• Adequate storage capacity was not available; EPA provided guidance that states State Directors
(meaning the chief administrative officer of the lead state agency) have the authority to establish
staging/storage areas that would be considered Part 257 facilities under federal rules (EPA,
2012).
• EPA provided guidance stating that State Directors have the authority to reopen closed
construction and debris (C&D), and municipal solid waste (MSW) landfills for the disposal of
disaster debris (EPA, 2012).
• EPA provided guidance stating that open burning is an allowable option under federal rules for
debris resulting from emergency clean-up operations (EPA, 2012).
• Prevention efforts (e.g., booms, skimmers, aerators) undertaken by the U.S. Army Corps of
Engineers (USACE) were reported to have had little effect on limiting any toxic chemicals, metals,
or pesticides in the discharged water (Esworthy et al., 2005).
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Best Practices for Management of Biocontaminated Waste
• EPA worked with states and USACE to develop guidance for the handling of polychlorinated
biphenyls (PCBs) and asbestos-containing materials (ACM) (EPA, 2012).
t II II >ola Virus Lessons Learn< 1
Ebola virus disease (EVD) is a recently recognized illness. Early recognition and treatment is critical to
controlling the spread and case-fatality rate. EVD first appeared in 1976 in two simultaneous outbreaks:
one in what is now Nzara, South Sudan, and the other in Yambuku, Democratic Republic of Congo. The
latter occurred in a village near the Ebola River, from which the disease takes its name. The 2014 Ebola
Outbreak was the largest recorded and the first in West Africa. The virus can be transmitted to people
from wild animals and spreads in the human population through human-to-human transmission. The
average EVD case fatality rate is approximately 50% (World Health Organization (WHO); 2015).
The CDC and partners took many precautions to prevent the spread of Ebola within the United States,
and CDC has since developed guidance for healthcare workers (hospital, laboratory, emergency medical
response, mortuary and funeral, and air medical transport) and non-healthcare workers (airline workers,
wastewater workers, humanitarian aid workers, decontamination, cleaning, and waste removal workers).1
Summary observations, recommendations, and/or information gaps stemming from the incident response,
as identified from a cursory review of the literature, are captured below.
• Create a WMP and secure necessary contracts and permits in advance to help avoid potential
exposure hazards, security risks, and storage problems. Pre-identify waste management facilities
prior to waste generation; waste management facilities may have their own requirements that
may need to be considered (OSHA, 2016).
• Do not use waste management processes that involve shredding incoming waste materials that
have suspected or confirmed Ebola virus contamination (OSHA, 2016).
• Place contaminated materials in double leak-proof bags and store in a rigid, leak-proof container
to reduce the risk of worker exposure. If waste ultimately will be transported, follow U.S.
Department of Transportation (DOT) guidance for packaging from the outset to minimize
repackaging or additional handling (OSHA, 2016).
• Ebola-associated waste may be incinerated. The products of incineration (i.e., the ash) can be
transported and disposed of in accordance with state and local regulations and standard
protocols for hospital waste disposal (OSHA, 2016). Ebola-associated waste disposal is subject
to state and local regulations. Ebola-associated waste that has been appropriately inactivated or
incinerated is not infectious and is not considered to be regulated medical waste or a hazardous
material under federal law (CDC, 2015).
• Community engagement is key to successfully controlling outbreaks (WHO, 2015).
3.5 Highly Pathogenic Avian Influenza Lessons Learned
Occurrence of HPAI in the United States has been very infrequent, has been contained, and normally
affects only birds. The Asian HPAI form, which is a subtype of HPAI, also known as H5N1, has been
found in Asia, Europe, and Africa, but not in the United States to date. H5N1 spreads very rapidly through
poultry flocks, causing mortality rates of domesticated birds that can approach 100% within 48 hours.
Hundreds of millions of domesticated birds have been killed by the virus or culled to prevent further
spread of disease. There have been some cases in Asia and Eastern Europe of HPAI H5N1 spreading to
1 The latest CDC guidance for healthcare workers can be found online: http://www.cdc.gov/vhf/ebola/ (Accessed July
18, 2016).
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Best Practices for Management of Biocontaminated Waste
humans through sustained close contact with live birds. The USDA has indicated that this virus has the
potential to generate large numbers of animal carcasses from the response to an avian influenza
outbreak (U.S. Environmental Protection Agency (EPA, 2006). In January 2015, an outbreak of avian
influenza subtype H5N2 was identified in a series of chicken and turkey farming operations in the
midwestern region of the United States. With the last case of the spring outbreak identified in June, 2015,
a total of 211 commercial and 21 backyard poultry premises had been affected, resulting in the
depopulation of 7.5 million turkeys and 42.1 million egg-layer and pullet chickens (APHIS, 2016). As a
direct result of this outbreak, the USDA published a plan in January 2016 for preventing and responding
to future HPAI cases, in collaboration with industry and state partners (APHIS, 2016).
Summary observations, recommendations, and/or information gaps stemming from the incident response,
as identified from a cursory review of the literature, are captured below.
• State and local stakeholders should put in place an emergency management plan through the
formation of an ad hoc team of experts (Beato et al., 2009).
• Infected animals should be rounded up quickly, euthanized humanely, and disposed of. It is not
recommended to store sick animals or carcasses for any length of time (Beato et al., 2009).
• Carcasses that will be transported must be contained in sturdy plastic bags. The inside of
transport vehicles may be lined with plastic as well in an effort to double-contain transported
carcasses. Bird carcasses may be composted, rendered, or incinerated (Beato et al., 2009).
• Trucks used for transport must be decontaminated using carwash-style practices with an
appropriate disinfectant followed by soap and water. The inside of the vehicle should be cleaned
using appropriate disinfectant. Emphasis should be placed on cleaning the undercarriage of the
vehicle (Beato et al., 2009).
• When selecting a location for composting, burial, or landfill, it is essential to plan away from
groundwater sources (Beato et al., 2009).
• Groundwater sources close to burial, landfill, and composting sites should be monitored closely in
the years following the outbreak. High levels of nitrogen, total dissolved solids, and chloride have
been observed (Beato et al., 2009).
• Composting is the preferred on-site treatment method. The compost pile must reach a minimum
of 130 °F, set for 11 to 14 days, turned inside out, and returned to 130 °F for at least two days.
After 28 days, the composted material can be released for off-site land application, stockpiling, or
incineration with approval from the IC (Minnesota Board of Animal Health, 2015).
• Factors important for successful in-house composting are the involvement of poultry companies
in managing the process, the formation of an expert team, the availability of carbon material and
letter, and the identification of response teams that are trained and equipped to compost flocks
within 24 hours of virus confirmation. In-house composting is the preferred method of disposal in
the United States (Beato et al., 2009).
• For the H5N2 outbreak, there were a number of pre-incident plans in place; however, responders
tended to focus on the emergency tasks at hand rather than refer to the plans to address the size
of the H5N2 outbreak and the magnitude of waste management activities associated with it. In
addition, there were too few responders with waste management expertise, and just-in-time
training is not possible for the level of complexity associated with waste management tasks.
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Best Practices for Management of Biocontaminated Waste
4. PLANNING ASSUMPTIONS
To facilitate management of waste generated from a homeland security incident, the EPA (2016b)
recommends that communities have a Pre-lncident WMP. The primary goal of pre-incident waste
management planning is to prepare a community to effectively manage waste, debris, and materials,
especially in larger quantities, which may include wastes, such as chemical, biological, and radiological-
contaminated wastes not typically handled. An all-hazards pre-incident waste management planning
process depicted in Figure 3 is a four-step process designed to help communities prepare for waste
management needs of an incident, regardless of the hazard.
This recommended process guides emergency managers and planners through four main steps that
cover the initiation, creation, updating, and implementation of a WMP. The waste management planning
process does not have to be completed at one time or by one person for a community. Pre-lncident WMP
guidelines developed by EPA's Office of Resource Conservation and Recovery (ORCR) are described in
Appendix A; a plan template outline is provided in Table A-1.
Step 1:
Pre-Planning
Activities
Step 4:
Incident-
Specific
WMP
Step 2:
Pre-lncident
WMP
Step 3:
WMP Review,
Maintenance,
Exercise, and Training
Conduct the following:
• Develop the pre-incident
WMP
• Use available tools for
assistance
• Coordinate with stakeholders
• Consult with WM facilities'
owners and operators
• Establish acceptance criteria
for reuse and recycling
Perform the following:
• Meet with stakeholders to review and update
the pre-incident WMP regularly
• Schedule and perform WMP exercises
• Develop training plan
• Incorporate WM lessons learned, after action
reports, and improvement plans
Plan/Do the following:
• Form planning team with federal, state,
local, tribal, and territorial WM officials
• Assume worst case scenario
• Identify key resources for the development
of the pre-incident WMP
• Determine regulatory issues/considerations
• Review existing plans
• Assess WM mitigation measures
Implement the following:
• Tailor the pre-incident WMP to
incident-specific conditions
• Present the incident-specific WMP
to the Unified Command
• Notify WM facilities of needs and
exercise contract support where
necessary
• Implement the community outreach
plan
• Track WM operations and report
progress
Source: (EPA, 2016b)
Figure 3. Pre-incident All-Hazards Waste Management Planning Process.
4.1 Pre-lncident Management Planning
Pre-incident planning identifies applicable regulations, possible options for managing the anticipated
waste, and waste acceptance criteria (WAC) for facilities. Pre-incident planning should be documented in
a Pre-lncident WMP. When an incident occurs, the Pre-lncident WMP can be tailored to the actual
incident, facilitating the waste management decision-making process during the incident. This plan should
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Best Practices for Management of Biocontaminated Waste
record discussions with transporters and facilities for waste treatment/disposal; include research and
tentative decisions regarding treatment and handling; consider health and safety requirements; and
develop waste management related community outreach. Specific factors to be considered when
developing Pre-lncident WMPs includes the following (depicted in Figure 4):
• Possible wastes and quantities;
• Decontamination strategy;
• Waste collection strategy;
• Appropriate treatment, storage, or disposal facilities;
• Transportation guidelines and requirements; and
• Staging/storage areas for managing waste.
As part of this plan, non-specific scenario information for critical infrastructure assets and characteristics
should be acquired, including a written record of information such as:
• Asset names and locations;
• Critical services provided by the asset;
• Dependencies between services and between assets;
• Workaround capabilities for services provided by each asset; and
• Milestone requirements for services and assets.
Additionally, restoration objectives and priorities should be considered and negotiated by emergency
planners, infrastructure owners, and other private and public stakeholders in neighboring jurisdictions
(New York City DOHMH, 2015).
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Best Practices for Management of Biocontaminated Waste
Interrelatedness of Pre-incident Waste Management Activities
Select Appropriate Treatment, Storage, or
Disposal Facility (TSDF)
Identify more than one facility due to limited
capacity, possible lack of acceptance by
facilities, etc.
Plan for temporary, secure storage sites
Initiate discussions with facilities to facilitate
their acceptance of incident waste
Determine facilities' waste acceptance criteria
Check facilities' permit status/compliance
Consider community and environmental
justice concerns
Review Transportation Guidelines and
Requirements
Determine how wastes should be
handled, packaged, labeled, and
transported
Incorporate strategies to limit the
spread of contamination
Consider separating wastes by type,
contaminant, treatment technology, receiving
facility, etc.
Include process to segregate wastes into
separate waste streams as soon as possible
Develop a Waste Collection Strategy
Establish Staging/Storage Areas for Managing
Waste
Consider on-site and off-site possibilities
Determine selecting criteria or suitable, secure
locations for sites
Plan for environmental monitoring
Scale plan to incident (small to large)
Establish waste minimization strategies
Consider potential reuse/recycling opportunities
Apply available technical information, regulations,
and guidance to the decision-making process
Identify Possible Wastes and Forecast Their
Quantities
Document Waste Management Strategies
and Activities in a Pre-incident Waste
Management Plan
Update plan regularly
Develop waste-related community
outreach and health and safety plans
Tailor plan to an incident, if necessary
Record discussions with transporters
and facilities
Include research and tentative
decisions
Determine the Decontamination Strategy
Test effectiveness of decontamination
technologies in meeting the established
clearance level
Analyze the tradeoffs between
decontamination and sampling versus
treatment and disposal
Prepare a sampling and analysis plan for
generated wastes
Consider waste generated from the
decontamination process
Source: (EPA, 2016b)
Figure 4. Pre-incident Waste Management Planning Considerations.
4.1.1 Available Management Tools
Table 6 provides examples of software management tools that may be useful for pre-incident planning for
a biological incident, including tools to address a B, anthracis attack. The contact information identified
for each tool may change overtime and may require reaching back to the software developers. Some
tools are directly related to waste management like l-WASTE DST, while other tools like the mapping and
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Best Practices for Management of Biocontaminated Waste
spatial software are indirectly related to waste management that could be utilized for pre-incident planning
purposes.
Table 6. Example Software Management Tools Available for Pre-lncident Planning.
Management
Software Tool
Function
Developer/Contact
Information
Prioritization Analysis
Tool for All-
Hazards/Analyzer for
Wide Area Restoration
Effectiveness
(PATH/AWARE)
Quantitative methodology for infrastructure
prioritization process and generation of
restoration timelines (biological incidents)
Sandia National Laboratories (a)
http://prod.sandia.qov/techlib/acce
ss-control.cai/2012/129466.pdf)
Accessed July 13, 2016.
FASTMap
Provides detailed GIS-based and statistical
data on important economic sectors as well
as the location of critical infrastructure and
economic assets at risk
Sandia National Laboratories (b)
http://www.sandia.aov/nisac/analv
ses/fast-analvsis-and-simulation-
team-fast/fastmap/Accessed Julv
13, 2016.
Decontamination
Strategy and
Technology Selection
Tool (DeconST)
Supports decision-making for the selection of
decontamination options for individual
specific buildings contaminated with B.
anthracis spores (expandable to address
other biological agents). Includes WM and
WM costs in the analysis of decontamination
options in facilitating the development of
facility-specific, remediation approaches.
Sandia National Laboratories
Incident Waste Decision
Support Tool (l-WASTE
DST)
Decision support tool that organizes large
amounts of information related to managing
waste resulting from incidents of national
significance (e.g., contaminated buildings and
natural disasters)
EPA NHSRC
http://www2.eraweb.eom/bdrtool/l
oain.asp Accessed Julv 13. 2016.
Building Restoration
Operations Optimization
Model (BROOM)
Indoor and outdoor data acquisition, data
management, and data analysis
Sandia National Laboratories
http://www.trb.ora/Main/Blurbs/15
5841.aspx Accessed Julv 13.
2016.
Visual Sample Plan
(VSP)
Statistical software program that estimates
sample sizes for given probabilities of
detection using estimated population
variability (compatible with BROOM)
Pacific Northwest National
Laboratory (PNNL-Battelle)
http://vsp.pnnl.aov/Accessed Julv
13, 2016.
Spatial Analysis and
Decision Assistance
(SADA)
Statistical software program focuses on cost-
benefit analysis and sampling location
University of Tennessee and Oak
Ridge National Laboratory
(ORNL)
http://www.sadaproiect.net/
Accessed July 13, 2016.
Fully Integrated
Environmental Location
Decision Support
(FIELDS)
Combines GIS, Global Positioning System
(GPS), database, analysis, and imaging
technologies to assist in environmental
cleanup efforts. Also available is F/S Plus
(combination of FIELDS and SADA)
EPA
https://www.epa.aov/superfund
Accessed July 13, 2016.
4.2 Nature and Consequences of a Biological Incident
A biological incident involves the natural, accidental, or intentional release of a pathogen or biological
toxin that affects humans, plants, or animals. The scenario described in this document is focused on a
deliberate attack against humans aimed to cause illness, death, fear, societal disruption, and economic
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Best Practices for Management of Biocontaminated Waste
damage. Unlike a chemical or nuclear incident, a biological incident may go undetected for hours, days,
or weeks depending on the agent used and the scenario employed, until humans or animals begin to
exhibit symptoms of disease. If there are no obvious or immediate signs of a biological incident, first
detection may be made by a local health care worker observing a pattern of atypical illnesses or by early
warning monitoring systems that detect airborne pathogens. For an aerosol release, the area impacted
would depend on the quantity of agent released, where the agent was released (indoors or outdoors), and
weather conditions. The persistence of the agent may be negatively impacted by the method of
dissemination as well as environmental conditions (e.g., sunlight, precipitation events, and relative
humidity) which can degrade, inhibit the spread, or otherwise inactivate the agent. Dispersion of a
biological agent released outdoors would generally occur in the direction of the prevailing wind, while the
spread of agents released indoors would be profoundly impacted by the building's air-handling systems.
Water and wastewater systems may also spread the agent vast distances while maintaining high
concentrations. Following deposition, the agent would be subject to relocation and human activity (vehicle
and pedestrian traffic) potentially causing secondary human exposures, which would continue to pose a
hazard throughout the entire response and recovery process. Re-aerosolization by weather (wind and
rain) only poses a hazard until decontamination is complete, not necessarily throughout the entire
recovery process.
The relative environmental stability of an agent can also impact its waste management. Some agents die
or inactivate rapidly when not in a suitable environment or a host, while others are adapted for existing
long term in the environment; it is even possible to formulate agents to increase their stability in the
environment. Heat, humidity, dryness, and ultraviolet radiation are all known to kill many microorganisms
in the environment. However, susceptibility to such factors varies by agent; for example, B. anthracis
spores can be less susceptible to these conditions than other agents. The environmental persistence of a
particular agent is an important factor in selecting the type and extent of remediation activities. Agents
that persist in some environments for only minutes or hours may require only minimal intervention for
decontamination.
4.3 Bioagent Waste Characterization
In general, the contaminated waste streams from a biological incident are likely to be highly variable,
ranging from building debris and contents (possibly as the result of demolition activities [e.g., concrete
rubble, structural metal, asbestos-containing materials, carpets, wallboard, electronics, etc.]) to
contaminated liquids (e.g., decontamination waste water) and sludge. Under DOT Hazardous Materials
Regulations (HMRs), 40 CFR 262, the generator of waste is required to determine whether the waste is
hazardous. For wastes not listed in this rule, waste generators may do this either by testing the waste
according to specified methods or through process knowledge.
Because biological threat agents are not identified as part of the federal hazardous waste
regulatory framework, it is very important that waste characterization and identification
requirements are consistent with state and local requirements, as well the WAC of potential waste
management facilities identified in waste management planning.
\ /
As previously discussed, Pre-lncident planning will greatly expedite the response and recovery timeframe
and thus reduce overall costs. Waste streams should be sampled and characterized early in the
remediation process to determine whether the surface of an article is contaminated prior to handling,
packaging, and transporting the article off-site (New York City DOHMH, 2015). It is possible for
characterization sampling efforts that are performed to cover the needed waste characterization
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Best Practices for Management of Biocontaminated Waste
requirements also, thus saving sampling time and analysis costs and helping to avoid overburdening
laboratories performing analyses.
4.4 Estimated Types and Quantities of Waste
Waste streams from a wide-area biological incident would originate from all phases of remediation and
would include contaminated indoor and outdoor materials, waste generated from personnel and
equipment decontamination, and waste generated from packaging and transporting contaminated
materials. The total could amount to hundreds of thousands or millions of tons and millions of gallons in a
large urban area. For example, the three major categories of biocontaminated wastes expected from
remediation are:
1. PPE and other materials associated with sampling and decontamination;
2. Materials discarded due to either damage caused during decontamination or technical difficulties
associated with proving that they have been effectively decontaminated; these materials may or
may not have residual contamination prior to handling as waste; and
3. Wastewater generated during decontamination, runoff from precipitation, and runoff from possible
flushing of water distribution systems.
It is highly likely that waste generated from a biological incident would be able to be separated based on
composition and item type (i.e., biological incidents will not likely generate large quantities of commingled
(mixed/blended) debris); therefore an effective segregation strategy can be very useful.
The quantities of waste expected to be generated, especially from a wide-area biological incident in a
large city, could include entire city blocks of high-rise buildings and public transportation systems. Thus, it
is anticipated that treatment and disposal capacities of the city and the surrounding areas are anticipated
to be exceeded, and regional and national support would be required to assist with the overall response
and management, amplifying the need for Pre-lncident WMPs to be developed and coordinated with
federal, state and local plans prior to an incident.
It is especially important because each state - and their permitted waste management facilities - may
have different requirements for biological agents, making it critical to have those requirements pre-
identified. Otherwise, waste may not be accepted by waste management facilities in other states.
tatimated Types and Quantities of B. anthracis Waste
The waste estimates for a B. anthracis incident will vary greatly depending on whether the
incident involves a single building or a wide area. Overall, substantial limitations constrain the
current ability to calculate waste estimates accurately for wide-area scenarios, reflecting
uncertainty in the understanding of the many processes involved in a response to a B. anthracis
incident of this magnitude and how these processes may impact waste quantities (New York
City DOHMH, 2015). For example, because total waste generated is strongly influenced by the
decontamination approaches chosen, uncertainties about how and which decontamination
options would be employed during a wide-area B. anthracis incident result in significant
variation in potential waste estimates. Waste management efforts are underway to continue to
increase the understanding of the connections between waste generated and processes such as
sampling and decontamination.
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Best Practices for Management of Biocontaminated Waste
A description of the expected waste streams and the appropriate classification of these waste streams is
shown in Table 8.
Table 8. Classification of Expected Waste Streams.
Description of Items/Waste
Waste
Classification*
Waste Management Facilities
Liquid Waste
Decontamination wastewater,
contaminated
HW, IW
Hazardous Waste Facility (e.g.,
incinerator)
Decontamination wastewater,
uncontaminated
NH/NI2
Publicly Owned Treatment Works
(POTW)3
Solid Waste
PPE, contaminated
HW, IW
Hazardous Waste Facility (e.g.,
incinerator)
PPE, contaminated
IW
Medical Waste Incinerator or
Autoclave
PPE, uncontaminated
NH/NI
Solid Waste Management Landfill
Office Waste and General Trash
(e.g., papers, PPE packing boxes),
uncontaminated1
NH/NI
Solid Waste Management Landfill
Building Materials (e.g., ceiling tiles,
drywall, carpeting), uncontaminated
NH/NI
Solid Waste Management Landfill
Furniture, uncontaminated
NH/NI
Solid Waste Management Landfill
Electronic Waste, uncontaminated
NH/NI
Solid Waste Management Landfill
* Waste Classification (as defined by federal, state, or local requirements as applicable)
• NH/NI: Non-hazardous and non-infectious through sampling or process knowledge
• HW: Hazardous waste as tested or through process knowledge
• IW: Infectious waste as tested or through process knowledge
1 Office waste is not removed from the contaminated site, but is generated by response activities, and not exposed to
contamination (or whatever the case may be).
2 Items in the categories currently labeled NH/NI are actually contaminated, they might be in the HW/IW categories if removed
rather than decontaminated on-site prior to transport and/or left in place (e.g., if drywall is removed from a contaminated facility for
disposal because it is porous, then it is not NH/NI).
Source: (EPA, 2015)
3 This can vary considerably; it should not be assumed that either the hazardous waste facility or the POTW will accept this. See
Water Environment Research Foundation [WERF] (2016) for more information.
4.5 Worker Health and Safety
Following a biological incident, the health and safety requirements for all workers should be addressed
and integrated into the overall mission of the response. Worker protection is a critical element of
biological waste management in the aftermath of a biological incident. These workers include emergency
responders, individuals that need to maintain critical infrastructure and key resources, and short- and
long-term remediation and restoration workers. Regardless of the biological agent(s), the following should
be addressed prior to managing any wastes:
• Understand the agent(s) of concern, exposure pathways, and all site hazards and risks.
• Federal workers are covered by OSHA requirements for federal agency occupational safety and
health programs (29 CFR 1960).
• Non-federal workers are subject to a variety of protection depending on industry, jurisdiction, etc.
All private sector workers are covered by OSHA. In states that operate their own OSHA-approved
State Plans, public-sector workers are also covered. EPA standards extend HAZWOPER
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Best Practices for Management of Biocontaminated Waste
protections to workers in states without a State Plan where federal OSHA covers private sector
(but not public sector) workers.2
• Consult public health agencies for recommendations on medical countermeasures (prophylaxis,
immunizations, and surveillance) prior to site response. Federal employees will be under the
jurisdiction of the USPHS recommendations; non-federal workers will be subject to local public
health recommendations.
• Consult with the federal, state, or OHSA staff on any specific health and safety guidance that may
develop as a result of the specific incident.
• Ensure that comprehensive site health, safety, and emergency response plans are developed for
the incident. Plans should address personnel medical clearance requirements, PPE, OSHA
requirements, exposure limits and medical monitoring, medical surveillance, emergency
response, site safety management, and training (discussed in Section 4.6) requirements.
o For cleanup operations, OSHA's HAZWOPER Standard (29 CFR 1910.120 or 29 CFR
1926.65) requires a written health and safety plan (HASP), which identifies site hazards
and appropriate controls to protect employee health and safety.
(¦ \
Requirements for HASPs for anthrax-contaminated sites can be found on OSHA's website
https://www.osha.gov/SLTC/etools/anthrax/hasp.html (Accessed July 18, 2016). Note: each HASP
should be tailored and specific to the incident and site.
4.6 Health and Safety Training
Personnel involved with waste management activities should be trained and possess the necessary
experience and skills, including an understanding of decontamination processes, how to handle biological
agents and biotoxins, the appropriate type and use of PPE (discussed in Section 4.6.1), appropriate
packaging and labeling requirements, and necessary health and safety procedures. OSHA requirements
for hazardous materials (HAZMAT) employees, as outlined in Standard 29 CFR 1910.120 or 29 CFR
1926.65, include the following training categories: general awareness/familiarization training for the
hazard, function-specific training, safety training, security awareness training, and in-depth security
training. Additional health and safety training for response personnel that may be required based on site
hazards is outlined in Table 7.
/ \
For a B. anthracis incident, OSHA addresses training for workers related to this agent during
response and remediation in an Anthrax eTool available online
https://www.osha.gov/SLTC/etools/anthrax/index.html (Accessed July 18, 2016).
2 EPA extends HAZWOPER protection to public sector workers in 40 CFR 311. EPA's purpose for adopting 29 CFR 1910.120 was
to cover employees that OSHA could not otherwise cover.
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Best Practices for Management of Biocontaminated Waste
Table 7. Personnel Training Requirements Overview.
Activity
Reference
Requirement
Emergency response to
hazardous substance release
HAZWOPER, 29 CFR
1910.120(q)(6)
24 hours training + depending on duties
Potential exposure to/working
with hazardous materials
HAZWOPER, 29 CFR
1910.120
Specific training on materials that may be
encountered/exposed
Potential exposure to bloodborne
pathogens
transmissible via blood,
certain body fluids, and
other potentially
infectious materials
Bloodborne Pathogens
(BBP), 29 CFR 1910.1030
Training requirements for exposure hazards,
exposure control plans, PPE, and other infection
control elements
Use of PPE (including respirator)
Respiratory Protection, 29
CFR 1910.134;
other PPE standards, 29 CFR
Subpart I
Understand when PPE is necessary; what PPE is
needed; how to put on and take off; limitations;
and proper care and maintenance
Working in noise hazardous areas
Occupational Noise
Exposure, 29 CFR 1910.95
Occupational Noise Exposure PPE, Training if
exposed above 85 dBA
Entry into confined space
Permit-Required Confined
Spaces, 29 CFR 1910.146
Awareness of confined spaces and training prior
to entry into permit required confined spaces
De-energizing circuits/ lockout/tag
out
Control of Hazardous Energy
(Lockout/Tagout), 29 CFR
1910.147;
Electrical Protective
Equipment (29 CFR
1910.137)
Specific program training on control of hazardous
energy
Potential exposure to hazardous
chemicals used for
decontamination
Hazard Communication, 29
CFR 1910.1200
Provide workers with information about chemical
hazards and how to protect themselves
Packaging, labeling, and marking
for transportation of infectious
waste
Hazardous Materials
Regulations (HMR), 49 CFR
172.704
Methods and procedures for avoiding accidents,
such as the proper procedures for handling
packages containing hazardous materials
Source: (New York City Department of Health and Mental Hygiene [DOHMH], 2015)
4.6.1 PPE for Personnel
All workers entering the exclusion zone or "Hot Zone" (illustrated in Figure 6 of Section 6) must wear
appropriate PPE, notably respiratory protection. NIOSH recommendations for PPE during a response to a
biological agent incident are based on site conditions and the dissemination method and nature of the
release (EPA, 2015). Recommendations are as follows:
• Employers of cleanup workers must provide respiratory protection with an appropriate filter to
protect workers from respiratory hazards. Cleanup workers are protected under the OSHA
Respiratory Protection standard (29 CFR 1910.134), which requires medical clearance, Attesting,
training, and other elements of a respiratory protection program beyond just provision of
respirators. Respirators must always be used in accordance with the provisions of the Respiratory
Protection standard.
• When the agent is unknown, dissemination with an aerosol-generating device is still occurring,
and/or the event is otherwise uncontrolled, NIOSH recommends that each emergency responder
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Best Practices for Management of Biocontaminated Waste
use a Level A protective suit with a NIOSH-approved, Chemical, Biological, Radiological, and
Nuclear (CBRN) pressure-demand self-contained breathing apparatus (SCBA).
• When the suspected biological aerosol is no longer being generated but other conditions may
present a splash hazard, NIOSH recommends that each emergency responder use a Level B
protective suit with a NIOSH-approved, CBRN pressure-demand SCBA.
• When the agent has been identified and it can be determined that: 1) an aerosol-generating
device was not used to create high airborne concentrations, or 2) dissemination was by a letter or
package that can easily be bagged, NIOSH recommends that each responder use a filtering
facepiece respirator (FFR) with a P100 filter or powered air-purifying respirator (PAPR) with high
efficiency particulate air (HEPA) filters. Some EPA requirements may necessitate the use of
NIOSH-approved CBRN-rated FFRs, though employers should be aware that FFRs and PAPRs
have different assigned protection factors.
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Best Practices for Management of Biocontaminated Waste
5. Mb vi- ru^a-iNc.v h'M i- >r \ ^ f • mi; >
In the United States, all levels of government - federal, state, territorial, tribal, and local - respond to
disasters. Incident management refers to how incidents are managed by government officials, between
multiple agencies and jurisdictions, and between phases of response and recovery (refer to Table 4).
Federal agencies provide critical assistance to state, tribal, and local response organizations in the event
of a disaster that overwhelms state and local capabilities. For incidents involving biological terrorism,
different agencies are responsible for coordinating activities specific to their area of expertise (DHS and
EPA, 2009). As discussed earlier in the document, the NRF provides guidance for response functions
immediately following an incident, including two incident annexes applicable to this SOG, the Biological
Incident Annex and the Food and Agriculture Incident Annex.
Response to biological incident will be managed using the incident command system (ICS) based on the
National Incident Management System (NIMS) (DHS, 2008d). ICS is a standardized, on-scene, all-
hazards incident management approach allowing its users to adopt an integrated yet flexible
organizational structure to match the complexities and demands of single or multiple incidents. ICS allows
facilities, equipment, personnel, procedures, and communications to be integrated and operated within a
common organizational structure. ICS coordinates response among various jurisdictions and public and
private entities and establishes a common process for planning and managing resources.
The response process will be managed by the IC/UC, which ultimately determines the structure and
organization of the Incident Command Post. A strong, coordinated IC/UC will be instrumental in
overcoming the challenges of biological agent waste management. Figure 5 shows an example of the
IC/UC structure following a biological incident.
In general, a wide area release of biological agents will make a response much more complicated, and
there is limited waste management expertise available across all levels of government to handle waste
streams that may never have been managed before. Therefore, these best practices recommend the
inclusion of a "waste management operations group" within the planning and/or operations section
comprised of pre-identified subject matter experts able to conduct the extensive level of coordination
required for wide area biological incidents that require waste management facilities across multiple states
and regions. Decisions regarding sampling, decontamination, strategies, public health and risk
assessment, and waste management will be made based on information from analyses conducted by
appropriate experts in the environment unit within the planning section (DHS and EPA, 2009).
The IC/UC is tasked with developing an overall decontamination strategy that will guide the development
and execution of all remediation activities. The overall goal of the decontamination strategy should be to
achieve the clearance goals (see Section 11) while reducing the expenditure of time and resources
required to recover a wide urban area following a biological incident.
Issues that cannot be resolved at the IC/UC level may be elevated to the Joint Field Office (JFO) Unified
Coordination Group for resolution. The JFO Unified Coordination Group may also wish to review and
provide input on decisions related to extensive contamination (and remediation costs) and in situations
where it may be necessary to set priorities among multiple contaminated sites (DHS and EPA, 2009).
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Operations
Section
Planning
Section
Support
Branch
Supply Unit
Medical Unit
Food Unit
Cost Unit
Time Unit
Liaison
Facilities Unit
Intelligence
Entry
Group
Decon
Group
Sampling
Group
Public Information
Site Access
Group
Logistics
Section
Ground
Support Unit
Resources
Unit
Contract
Support Unit
Situation
Unit
Procurement
Unit
Finance, Admin
Section
Info/Technology
Unit
Compensation/
Claims Unit
Communications
Unit
Demobilization
Unit
Environmental
Unit
Incident/Unified
Command
Documentation
Unit
Waste
Management
Operations Group
Deputy
Incident/Unified
Commander
Source: (DHS and EPA, 2009)
Figure 5. Example of incident command structure for biological incident.
5.1 Resource Personnel Needed from Response Management
It is critical to identify the waste management resource personnel and wastewater management
authorities that will be needed at the federal, state and local level since federal response teams will not
necessarily have the knowledge of the state and local facilities and resources, unless they have
familiarized themselves ahead of time. Experience has demonstrated that representatives from the local
public works departments including the sanitation, water and wastewater departments will be needed, as
well as the local planning and transportation departments (i.e., access to city and facility maps/drawings),
as they are critical for waste management activities including staging, transportation, storage, and
packaging.
In addition, vetted sampling teams and contractors, environmental monitoring teams and contractors,
data management and documentation specialists, PRE suppliers, facilities engineering and construction
teams, fate, transport, and exposure pathway modeling teams and contractors, and decontamination and
fumigation teams with adequate training and resources should be used to perform necessary duties.
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6. BIOAGENT WASTE MANAGEMENT OPERATIONAL CONCEPTS
For most scenarios involving a wide-area release of a biological agent, unprecedented amounts of waste
would be generated during remediation. The initial stages of the waste management process, but also
specific factors (refer to Figure 4) to be considered when conducting pre-incident planning, involve
identification, segregation, and staging or temporary transfer of waste generated from response
operations. Further needs to consider include anticipated waste streams, sampling and analysis for waste
classification and identification, and WAC associated with different waste management options/facilities.
As soon as possible after determining that a biological release has occurred and emergency public health
issues are addressed, it is necessary to distinguish among, and set boundaries for, three preliminary
zones. The standard zone designations depicted in Figure 6 are used to guide subsequent cleanup and
environmental sampling activities and to reduce contamination as well as the likelihood of
recontamination of areas already cleared (DHS and EPA, 2009).
¦ Areas where contamination is either known or expected to occur and where the greatest potential
for future exposure exists. Access to and egress from an exclusion zone should be restricted to access
control points. All persons who enter an exclusion zone must wear the appropriate level of PPE for
the degrees and types of hazards present (per OSHA guidance).
¦ Areas surrounding a Hot Zone (likely quite large in extent in a wide-area attack) that may pose low,
but some potential health risk. Here, decontamination takes place for personnel, equipment, and
items coming out of the Hot Zone. Such zones are the transition area between an exclusion zone and
support zone (see below). The purpose of a contamination-reduction zone is to reduce the possibility
that a support zone will become contaminated or affected by site hazards.
• Uncontaminated areas that may be safely used as planning and staging areas where workers are
unlikely to be exposed to biological agents or dangerous conditions. Because support zones are free
from contamination, personnel working within them wear normal work clothes. Support zones are
designated as such from all available site characterization data and should be located upwind from
exclusion zones. Cold zones may change in response to environmental conditions such as wind and
rain and must be monitored over time.
Exclusion Zones ("Hot Zones")
Contamination-reduction Zones ("Warm Zones")
Support Zones ("Cold Zones")
Figure 6. Contamination Site Standard Zone Designations.
OSHA Anthrax Risk Reduction Matrix
The designations in Figure 6 should not be mistaken with OSHA's three risk zones of categorizing
the likelihood of anthrax-contaminated worksites: green, yellow, and red, where the green
indicates contamination with anthrax spores is unlikely, yellow indicates contamination with
anthrax spores is possible, and red indicates contamination with anthrax spores has been
confirmed or is strongly suspected. This information can be found separately online at:
https://www.osha.gov/SLTC/etools/anthrax/risk_eval.html (Accessed July 18, 2016).
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Best Practices for Management of Biocontaminated Waste
-site Decontamination
When on-site decontamination is going to be performed, technologies that can be used as barriers in
preparation for decontamination include sheeting materials used as isolation barriers inside a facility;
building tents to seal structures; and sheeting to cover glass for ultraviolet protection. Sheeting materials
and tarps can also cover and confine outdoor areas identified as hot spots or as physical barriers for
fumigants applied outdoors. Other materials such as sealants and tapes (e.g., glues, foam, and caulking)
are required to provide airtight seals and to cover joints and nails. Materials used as part of fumigations
should have gas-resistant properties and provide airtight installations.
In preparation for outdoor decontamination, initial actions such as application of surface fixatives or
binders, or physical removal by a variety of methods should be taken to prevent the spread of
contaminants. These initial actions are advantageous because they can inhibit potential resuspension
and cross-contamination, while allowing additional time for response personnel to consider prioritization,
response planning, and actions for more thorough follow-on decontamination. For indoor facilities where
fumigations or liquid decontamination will be performed, prior HEPA vacuuming may be used, especially
on porous surfaces, to physically remove the agent from the item and reduce the amount of contaminant
that can interfere with subsequent decontamination.
The following recommendations are provided to maximize the efficiency of biocontaminated waste
handling operations while minimizing exposure to the personnel involved in the process:
Best practices to minimize exposure
• Construct appropriate isolation barriers using appropriate sheeting materials for specified
decontamination methods;
• Use sealants and tapes to provide airtight seals and to cover joints and nails;
• Perform source reduction of materials as appropriate for outdoor and indoor sites; and
• Prevent contaminated water from decontamination operations, precipitation run-off, etc. from
running off into uncontaminated areas.
To prevent further contamination or an unintentional release into the environment or the community, all
personnel, PPE, tools, machines, structures, devices, vehicles, and surfaces that have been in contact
with the suspected biological waste should be decontaminated or treated before being sent to an
authorized recycling or waste management facility. Based on past emergency response efforts, it is likely
that all waste will be required to be decontaminated before transport to disposal facilities. Therefore,
waste should be minimized, and decontamination strategies should incorporate in situ (or on-site)
decontamination (see Section 6.2.1) and reuse whenever possible (Raber et al., 2011).
Recommendations for managing waste generated during decontamination of humans, animals, site
premises, and vehicles are listed below. Potential decontamination technologies and their appropriate
application is presented later in Section 8, Table 10.
8.2 Human Decontamination
CBRN incidents present different challenges for all responders, necessitating the rapid decontamination
and treatment of a significant numbers of casualties while taking critical measures to ensure the well-
being of the personnel managing the incident. Decontamination of personnel after a biological warfare
attack is a lesser concern than after a chemical warfare attack for instance because most biological
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Best Practices for Management of Biocontaminated Waste
warfare agents are not dermally active. Still, decontamination remains an effective way to decrease the
spread of infection from potential re-aerosolization.
If personal decontamination is deemed appropriate, persons (e.g., victims) should remove their clothing
and personal effects, place all items in plastic bags, and shower using copious quantities of soap and
water. All workers entering the exclusion zone or Hot Zone must don and use/wear appropriate PPE for
all steps, notably respiratory protection. Located in the designated Warm Zone of an incident will be a
decontamination station to decontaminate workers and their equipment when exiting the Hot Zone.
Decontamination in the Warm Zone ensures that individuals are not contaminated by materials in the Hot
Zone while removing their PPE and that they do not contaminate the clean site of the area (Cold Zone).
For human decontamination, mechanical decontamination is conducted to physically remove the potential
contaminant by washing with soap and water. For PPE or non-sensitive equipment, chemical
decontamination is performed by applying disinfectants to inactivate the biological agent.
The objective of disaster triage (field triage) is to do the greatest good for the greatest number of people.
Effective triage requires significant planning and an infrastructure that can support the process during a
disaster. Trained and qualified triage personnel should determine priority of treatment and
decontamination. In addition, the various decision-making activities related to decontamination should be
executed in a flexible manner, depending on the victim's general state, the physical nature of the agent
(gas, aerosol, droplet, splash, liquid, powder, etc.), as well as the season, weather conditions, and other
factors (Okumura et al., 2007).
Decontamination triage is the prioritization of victims for decontamination based evidence of
contamination and/or exposure to the hazard. It is a prioritization mechanism used by first responders to
determine whether victims emerging from a biological incident scene should be directed to area(s) of safe
refuge/observation area or to a mass casualty decontamination station. Note: Decontamination Triage is
not the same as Medical Triage, which is performed to determine who should receive medical treatment
first (Lake et al., 2013). No medical care is provided to patients during the time spent waiting to begin the
decontamination process. Therefore, the patient must be stabilized to an extent that their condition will
not deteriorate during this time. In a contaminated environment, emergency care is given by personnel in
the highest level of mission-oriented protective posture, whose capabilities are limited by their protective
gear. After receiving emergency care, a casualty must go through the decontamination station before
receiving more definitive care in a clean environment (Ramesh and Kumar, 2010).
According to Lake et al. (2013), principles of mass casualty decontamination for a biological incident
include:
1. Time is critical in order to save the most lives; a) the immediate removal of clothing outside the
contaminated area for patients who have been visibly contaminated or who have been suspected
of having been contaminated and b) processing the victims through a high-volume, low-pressure
water shower (~50 to 60 pounds per square inch [psi]) is priority. This may aid in the removal of
80-90% of physical contamination in almost all cases.
a. Initial decontamination wash time should be between 30 seconds and three minutes
in duration to ensure thorough soaking, depending on the situation and agent involved.
b. Safe/refuge observation areas should be utilized to monitor victims for signs of delayed
symptoms or evidence of residual contamination.
c. Secondary decontamination should be performed as necessary, where the setup of
secondary decontamination should not delay primary decontamination.
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Best Practices for Management of Biocontaminated Waste
2. Provide effective mass casualty decontamination. Other activities, such as setting up commercial
decontamination tents, tarps, additional decontamination equipment, and/or creating a soap-
water solution should be accomplished when time permits.
3. Conduct decontamination triage prior to administering a high-volume, low-pressure water shower.
4. Use gentle friction (such as rubbing with hands, cotton flannel or microfiber cloth, or sponges) is
recommended to aid in removal of contamination. Rubbing should start with the head and
proceed down the body to the feet. Extra care should be taken to prevent the spread of
contamination to the mouth, nose and eyes (such as holding one's breath to avoid
inhalation/close contact with mucosa and closing one's eyes while wiping the face and head).
If on site treatment is not possible or advisable, wastes may have to be properly packaged and
transported to a state or locally approved waste-treatment facility capable of destroying any remaining
spores. Depending on the capacity of available facilities and the size and volume of wastes to be treated,
medical or other equivalent types of waste-treatment facilities might need to be used (Raber et al., 2011).
Sensitive items may be moved to another spot within the site for decontamination by placing the item in a
large standardized shipping container (i.e., Conex box) or other enclosure near the decontamination site
(New York City DOHMH, 2015). Items designated for off-site decontamination will need to be removed
and labeled/tagged for tracking and enclosed to avoid contamination during transport. Once inside the
enclosure (i.e., Conex box), the items can be fumigated using techniques suitable for sensitive items
(e.g., ethylene oxide) allowing them to be treated for reuse.
'tu Waste Decontamination for B. anthracis
B. anthracis-contaminated waste may be stored for further treatment or pending If personal
decontamination is deemed appropriate, persons (e.g., victims) should remove their clothing
and personal effects, place all items in plastic bags, and shower using copious quantities of
soap and water. Plastic bags with personal effects should be labeled with the owner's name,
contact telephone number, and inventory of contents. Personal items may be kept as
evidence in a criminal trial or returned to the owner if the threat is unsubstantiated. Evidence
or personal items should be double-bagged and decontaminated on the outside with an EPA
approved sporicide (e.g. PERIDOX ® or Steriplex Ultra™) prior to removal from the Hot Zone.
Note: To-date, these are the only two liquid sporicides approved by EPA effective against B.
anthracis. If possible, B. anthracis-contaminated wastes should be treated on site to reduce or
destroy spores, tested to confirm treatment effectiveness, and treated further, if necessary,
until post-treatment sampling shows no indication of viable spores. If such a process is
followed, treated wastes may possibly be disposed of as municipal solid waste (MSW) or
wastewater, given approval from appropriate state and local authorities. However, the
procedure for obtaining such approval is not currently well defined, and state and local
authorities may face technical and non-technical challenges when determining if such
approval is warranted (WERF, 2016).
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Best Practices for Management of Biocontaminated Waste
6.3 Animal Decontamination
Animal decontamination is a complex mission area that requires a commitment of time and the
engagement of those with expertise in the science and management of animals and hazard incidents.
Without such commitments, responders may be exposed to additional health risks and animal suffering
may be increased. Animal decontamination should be integrated into the overall planning when
conducting exercises for actual incidents. Local or state incident management teams may consider
incorporation of Animal Branch Managers or Animal Group Supervisors as an element of their planning
process. Animal agencies or organizations should participate in training and exercise programs with
emergency managers and planners when appropriate to facilitate familiarity with all aspects of hazardous
materials incidents and identify additional capability/training needs. Planning should be conducted for
diverse animal groups, which may include the following:
• Service animals;
• Working animals;
• Pets (from households and animal facilities such as from veterinary hospitals, animal
control/shelter facilities, boarding kennels, and pet breeding facilities);
• Livestock and poultry;
• Wildlife (native/free-ranging and managed, such as from zoos, aquariums, sanctuaries, etc.); and
• Research facility animals.(National Alliance of State Animal and Agricultural Emergency
Programs (NASAAEP) Best Practices Working Group, 2014).
Veterinary and animal care personnel working anywhere in the animal decontamination line should at a
minimum be in the same PPE as the unit conducting other types of decontamination activities. A triage
tent for veterinary care should be planned prior to the decontamination line to determine if the animal is
contaminated, or has any life, limb, or eyesight injuries that need to be treated, or what to do with the
animals that are likely to develop disease following the incident (e.g., if they have ingested, inhaled, or
otherwise been exposed to a pathogen with a certain latency or incubation period). Animals with major
injuries may need to be stabilized prior to decontamination when resources are available. If such
resources are not available or if providing veterinary care creates an unacceptable risk to responders
(e.g., severe injury or illness), euthanasia may need to be considered. Uncooperative or dangerous
animals may need to be sedated prior to decontamination.
Mass animal decontamination may be necessary from a wide-area event and may require gross
decontamination and/or temporary sheltering the animals in a Warm Zone. Equipment used in the
decontamination of humans or equipment may be applicable to animal decontamination. The animal may
need to be decontaminated several times before it is considered "clean" enough to be near unprotected
people. If animals ingest contaminants, the animal's waste may then be contaminated and need to be
handled as such; therefore, consideration should be given to a method of collecting and testing the
animals for contamination. A triage tent for veterinary care should be planned at the end decontamination
line as well to reassess the animals after decontamination to determine if they are healthy enough for
transport or clean enough to leave the site. Following decontamination, signs of internal contamination or
future disease development will need to be monitored for by the owner or the receiving shelter or
veterinary clinic (NASAAEP Best Practices Working Group, 2014). A latency period should be determined
by veterinary staff.
If deemed necessary, animals should be euthanized in accordance with the American Veterinary Medical
Association (AVMA) guidelines (AVMA, 2012). Depending on the incident, it may be unrealistic to follow
these guidelines due to responder safety and/or resource availability (e.g., in incidents involving large
populations of livestock or poultry, these operations are referred to as depopulation rather than
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Best Practices for Management of Biocontaminated Waste
euthanasia). In general, performing life-ending operations requires owner permission or direction from the
appropriate regulatory authority (NASAAEP Best Practices Working Group; 2014). If laboratory analysis
of carcasses is needed, a protocol for sample collection and submission must be developed prior to the
emergency.
When euthanizing animals, procedures for how carcasses will be disposed should be determined.
Carcass disposal may be by burning, burial, composting, or rendering, pending state and local approval.
A list of rendering plants, crematoria, and heavy earth-moving equipment suppliers should be identified in
the response planning. If mass burial is to be conducted, state and local environmental officials should be
consulted to ensure that the burials will not contaminate water sources or harm other natural resources
(AVMA, 2012). On-site management (e.g., on-site composting) minimizes biosecurity concerns involved
in moving contaminated carcasses, animal products, and other materials off an affected premise(s). On-
site composting has been shown to be a successfully used practice based on its effectiveness by
inactivating the virus in avian influenza outbreaks. However, USDA recognizes that not all types of poultry
operations (e.g., live bird markets) lend themselves to on-site management. Therefore, secure transport
to an off-site treatment/disposal facility may be necessary (EPA, 2006).
8.4 Premises Decontamination
Decontaminating an area contaminated by a biological agent involves numerous issues specific to an
individual location. For example, hard, nonporous surfaces can be treated relatively effectively with a
variety of decontamination approaches, whereas outdoor surfaces can be highly porous or contain large
amounts of substances that can react with the decontaminant or otherwise interfere with efficacious
decontamination (e.g., organic components in soil and dust) and therefore require careful evaluation to
determine an effective decontamination strategy. In general, on-site treatment options include HEPA
vacuuming, anti-microbial disinfectants, and fumigants. Specific examples of decontamination methods,
their suitable usage conditions and phase of use during the decontamination process (source reduction or
treatment), and handling post-decontamination are outlined later in Table 10.
Prior to off-site decontamination, gross decontamination can be conducted, generally involving performing
preliminary surface treatments and physical removal of items not conducive to decontamination. In some
circumstances, gross decontamination may be sufficient to achieve the clearance goals. Gross
decontamination may involve the following activities:
• Treating identified hot spots;
• Removing items/materials not conducive to decontamination methods;
• Cleaning surfaces to facilitate decontamination methods; and
• Decontaminating non-removable, sensitive items in situ.
6.5 Vehicle Decontamination
During a response, there will likely be two basic categories of vehicles present:
• Commercial/industrial vehicles, including emergency response and service vehicles (i.e., fire
trucks, squad cars, ambulances, hearses, buses); and
• Personal (commuter-type) vehicles (i.e., family cars, taxis, vans).
It may be useful to dedicate some commercial/industrial vehicles to the exclusion zone (Hot Zone) where
PPE is routinely worn and to subject the vehicles to routine washing with a bleach solution to control
excessive contamination. At the conclusion of the response action, a comprehensive decontamination of
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Best Practices for Management of Biocontaminated Waste
each vehicle would be needed prior to returning the vehicle to normal duty (New York City DOHMH,
2015).
Vehicle decontamination is particularly challenging since most vehicles are primarily made up of porous
surfaces, and they have HVAC systems that cannot be directly accessed. It may be beneficial to evaluate
the degree and location of contamination on the vehicle interior and exterior surfaces and HVAC system
before beginning the decontamination. This assessment should include a history to determine if the
vehicle was in an area where contamination was present and the operating state of the vehicle at the
time. Many options are possible, including the following:
• The vehicle may have been parked, not operating, and secured at the time of the release;
• The vehicle may have passed through/by the contamination plume;
• The driver may have tracked contamination into the vehicle; or
• The vehicle may have been sitting in traffic with the HVAC operating or the windows open when
the plume passed by (New York City DOHMH, 2015).
Understanding the level and character of contamination would allow for the decontamination method(s) of
least complexity to be employed and field tested during the incident. For example, if sampling verifies that
contamination was merely tracked into the vehicle, then a thorough shampooing with a decontamination
agent of the carpets, seats, and other surfaces may be adequate to return the vehicle to its owner. For
personal vehicles, if the vehicle is contaminated to any real extent, fumigation might be the most reliable
method to render it safe for use (New York City DOHMH, 2015).
The EPA has developed a "Quick Reference Guide" for addressing decontamination of vehicles that enter
the Hot Zone after an incident has taken place (EPA, 2016c). Examples include vehicles used for the
purpose of transporting personnel for sampling, decontamination, evidence collection, law enforcement,
retrieval of high-value items, or similar activities. Following development and review of a decontamination
plan, pre-entry strategies should be implemented in an effort to decrease decontamination efforts
including (EPA, 2016c):
• Replacing porous, difficult-to-decontaminate vehicle parts with nonporous, easier-to-clean parts
to facilitate cleaning and application of decontaminants, when possible.
• Adding enhanced cabin filtration by replacing the cabin air filter with a higher-efficiency cabin air
filter that is appropriate for the agent.
• Covering non-replaceable, porous equipment, tools, and vehicle parts (e.g., seat cushions,
electronic components) with plastic that can minimize the need for decontamination.
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Best Practices for Management of Biocontaminated Waste
7 SOU!I >1; I?r ! CI ION, HI a II U [ -1 :il I- lf ?-\[\>
PACKAGING, IFOR BIOCONTAMINATED WASTE
Waste management activities following a biological incident may include methods and protocols for waste
handling, treatment, packaging, transportation, and disposal operations. A strategy for waste
management activities should identify a process flow of waste to include where waste will be generated,
what waste will be generated, how much will be generated, the rate of waste generation, and the physical
state (solid, liquid, gas) of the waste (EPA, 2015).
isle Handling
Reducing the number of times the waste is handled and facilitation of a smooth, timely, and efficient
response is important. Items intended to be recycled or discarded as waste should be separated as soon
as feasible, including on site, to allow creation of waste streams that can be managed in a manner most
appropriate for each waste stream. In addition to waste generated during remediation activities, there will
be a large number of patients seeking medical treatment in this type of scenario, thus causing an
increase in waste generation at medical facilities. Therefore, the handling of this medical waste should be
addressed as part of pre-incident planning, otherwise it will interfere with the overall cleanup and recovery
effort for the remaining impacted area. Further, while the response and recovery is occurring, normal
waste management practices still need to occur for those areas outside the contaminated area; normal
waste also may increase as people dispose of their marginal belongings (believed to be uncontaminated)
creating a larger flow of normal waste. The handling of this waste should also be planned in the overall
incident response because there will be competition for the same disposal resources.
In an effort to aid in the waste management activities, a visual depiction of the waste flow may be helpful.
The example diagram shown in Figure 7 identifies where and how the waste may be generated, the types
of waste likely to be generated, the physical state of the waste, and steps guiding the management of
waste from a biological incident. This type of visual depiction enables waste management decisions
based upon an understanding of the incident, the release, and the overall response strategies. Note that
this is an example generated for a particular purpose, and that such a diagram arise from a particular
incident may look significantly different. The contents of the example should not be taken to infer a
general recommendation.
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Best Practices for Management of Biocontaminated Waste
1 Contaminated Biohazard
Waste Inducting:
Untreated Building
Decontamination
Materials, PPE.
Untreated Waste
Liquids, etc.
1 Contaminated Vehicles
Resident's Self
Response
Disinfected Clothing
Disinfected Waste
Hazardous W
Requires a Part 364 Permit
(Unless Incinerated)
•Authorized Regulated
Medical Waste Combuitor
or Treatment F
Authorized Hazardous
Waste Treatment,
Storage or Disposal
Treated Decontamination
Liquids (See USE PA Gu idance
for Containment & Disposal of
Large Amounts of Contaminated
Water. 20121
Legend:
Untreated Waste 1
TrMtwl Wast* I
¦ Authorized Solid Waste
Disposal Facility
¦ Options Include: Solid
Waste Landfills or
Municipal Waste
Combustors
Authorized Vehicle
Dismantler or Returned to
Owner
Authorized Publicly
Owned Treatment
Works If Liquid &
Treated
Disinfected Waste
HAfj rttau* Wastp
Resident's Self Response Waste {Wide Area On*y| ¦¦
Disinfected Waste means Application of an antimicrobial agent to
reduce the concentration of micrcKXgatusrm but« not considered
treatment,
r/efflmeflt means a process that changes the character of the waste so
that It ra> loi'oef poses a threat to public health or the enviroiwnent
Source: (New York City DOHMH, 2015)
Figure 7. Waste Management Flow Chart for a Biological Incident.
7.2 Segregation and Source Reduction
Segregating the waste before other activities (e.g., packaging and transportation) minimizes costs and
maximizes environmental benefits. Therefore, a collection strategy should be developed, preferably prior
to an incident or immediately after an incident, that allows for separating the waste based on contaminant,
material type, or management method.
Prior to the commencement of decontamination activities, certain items and/or materials may be removed
from a contaminated site for further treatment and reuse or disposal. As previously discussed, items
remaining on-site and/or surfaces may be cleaned before the main decontamination event. This
preliminary cleaning is performed in an effort to: 1) reduce the number of potentially contaminated
items/materials present, 2) remove any material that might inhibit decontamination, and 3) reduce high
levels of contamination prior to full decontamination (DHS and EPA, 2009).
The items that are subject to removal can be grouped into essential (sensitive) or non-essential items, as
outlined in Table 8.
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Best Practices for Management of Biocontaminated Waste
Table 8. Source Reduction Material Categories.
Item/Material
Designation
Description
Examples
Essential
Items that must be protected, removed for
decontamination elsewhere (e.g., regulated
sterilization facility), and saved or restored
for later use
Certain artwork, essential
computer data, expensive
medical equipment, valuable
documents
Non-essential
Items that must be removed, treated, and
disposed or recycled. The time and cost to
remediate items for reuse needs to be
evaluated against the time and cost to
dispose as waste.
Site debris, items that may
inhibit decontamination, low-
cost items, exposed
foodstuffs, exposed
perishables
Information derived from: (Raberetal., 2011); (DHS and EPA, 2009).
Decisions for which non-essential items will be removed from the contaminated site will have to be made
on a case-by-case basis. Cost-benefit analyses for removing the items versus performing the
decontamination in situ will need to be performed. In general, non-essential items removed from the site
are pre-treated (e.g., diluted bleach), as appropriate, and placed in packaging specified by the DOT and
state and local governments. Essential items are not pre-treated and are packaged the same as non-
essential items. These packaged items are then treated, removed from the facility and transported to the
appropriate off-site facility (discussed later in Section 10). The items will then be disposed of as waste or
further treated for disposal, recycling, or reuse (DHS and EPA, 2009).
The following recommendations are provided to maximize the efficiency of biocontaminated waste
handling operations while minimizing exposure to the personnel involved in the process:
Best practices to minimize exposure
• Clearly label and segregate waste into essential and non-essential items;
• Separate segregated items based on material type and/or management method;
• Promptly perform source reduction outdoors to reduce contaminant load and the potential for
spread early after an incident;
• Limit number of workers involved in these source reduction activities;
• If it is known that settled bioagent (e.g. B. anthracis or biotoxin aerosols) exists, use
suppressants by misting or wetting area, without producing significant amounts of runoff water,
to reduce airborne concentrations and the likelihood of re-aerosolization and airborne
exposure;
• Vacuum surfaces only with a system containing HEPA filters;
• Vacuum debris captured in HEPA filters must be double-bagged, bleached, and
decontaminated before disposal in off-site waste handlers; and
• Appropriately decontaminate any residual bioagent remaining on a surface following
vacuuming.
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Best Practices for Management of Biocontaminated Waste
7.3 Waste Staging
Relevant issues to consider in evaluating staging and temporary transfer locations include whether the
waste will be protected from weather and if there are methods to ensure that there is no release of
contaminants, security measures against vandalism are in place, and monitoring is available. In the event
the primary staging and temporary transfer areas or the potential management facilities identified in the
Pre-lncident WMP are no longer available following an actual incident, alternatives to these types of sites
or facilities should be identified in advance and documented in the Pre-lncident WMP.
The amount of time the waste is held at the staging location prior to transport off-site should be limited.
Waste contaminated with an infectious agent should not be staged for more than 14 days or placed at
temporary transfer locations longer than necessary (New York City DOHMH, 2015). In cases where it is
necessary to store the waste for an extended period of time, approval from a regulatory agency may be
required (New York City DOHMH, 2015).
If the waste is staged on vehicles, local and state requirements may preclude queuing these vehicles on
streets. Therefore, responders and waste transporters should pre-identify in the WMP (or identify early in
the response) how and where waste will be staged and identify short- and long-term staging or temporary
transfer capacity, both on- and off-site. Waste should be staged in the transport vehicles where feasible
(New York City DOHMH, 2015).
If specific sites cannot be identified in advance, a list of selection criteria for selecting appropriate sites
should be identified during the pre-incident planning stage, so that when an incident occurs there is an
accessible way to identify and select from suitable sites. Selection criteria may include such items as
drainage, accessibility, proximity to wetlands, potential for impact to endangered species, environmental
justice concerns, etc.
The following recommendations are provided to maximize the efficiency of biocontaminated waste
handling operations while minimizing exposure to the personnel involved in the process:
Best practices to minimize exposure
• Choose location(s) with an understanding of the workflow around the activity being staged,
considering the size of the area required and protection from environmental factors;
• Clearly identify the purpose for activities to be conducted in the staging area(s), and the
individuals who are authorized to enter the area(s);
• Verify that methods employed do not cause an unintentional release/spread of contaminants;
• Limit the amount of time contaminated waste is staged;
• Implement security measures and monitor the staging area(s);
• Stage packaged untreated waste or waste that has not been effectively treated by waste type
in separate primary containers and in separate locations from waste that has been effectively
treated to meet the established clearance level; and
• Place properly packaged untreated or ineffectively treated waste on an impermeable surface,
labeled and secured to prevent unauthorized access. Use additional containment methods,
such as berms and absorbents, as necessary, to prevent a liquid release.
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Best Practices for Management of Biocontaminated Waste
7.3.1 Waste Packaging and Tracking
It is important to note that DOT HMRs govern packaging and transportation. Refer to Section 10.1 for an
overview of the DOT and CDC regulations for transporting hazardous materials. Items that require
treatment off-site might be appropriately packaged prior to transport. For instance, treated and untreated
waste might be placed in a bag (primary container), sealed, labeled, and, if possible, placed in a second
bag before being placed in metal or fiberglass bulk outer packaging or a caster cart. After sealing, the
outside of each bag and the outer packaging might be cleaned with a sodium hypochlorite solution prior
to being transported off-site (New York City DOHMH, 2015). The relevant authorities should be consulted
to determine if waste containers require special markings (e.g., biohazard). For agents that are
bloodborne pathogens, employers may also need to comply with OSHA BBP standard packaging
requirements. Also, if treating off site, there may be a need to comply with provisions of a DOT special
permit for waste hauling.
Sensitive items should be tracked by establishing a label/tag system such as using evidence tags or
labeling bags with a predetermined nomenclature system. Bar coding or other electronic tracking may be
the most efficient method, given the quantity of items that will probably need to be handled. Example
specific step-wise guidelines (derived from New York City DOHMH, 2015), for removing such items are
summarized in Figure 8.
Bag the item
• Double
heavy duty plastic
resistant to punctures. Large items
may be double wrapped in heavy
duty plastic sheeting (e.g., visqueen).
sensitive items using
most
Track
•The location and disposition of the
sensitive item should be tracked
electronically (in accordance with an
approved Data Management Plan)
Tape the bags shut
• Use duct or other tape with similar or
better adhesive properties to tape
the bags shut. Large items wrapped
in plastic sheeting should be taped to
secure all edges of the plastic to the
item.
Label or Tag the bag
• Label the bag or wrap using the
established labeling system for
sensitive items to be moved with
permanent markers and labels.
Ensure that markings are dry so that
they are not smudged during
transport.
Document
• Using a Chain of Custody (COC) form
and any other form/logbook, as
decided upon during the response, to
document the items.
Disinfect
• The surface of the container/bag
should be decontaminated (e.g.,
sodium hypochlorite solution) prior
to placing the container in a shipping
area/container.
Transport
•The
location for off site decontamination.
It may be necessary to further place
the bags into another container for
transport (e.g., drum, Gaylord 30
box, roll off box).
are moved to a secure
Figure 8. Packaging and Tracking Process for Sensitive Items for Off-site
Decontamination.
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Best Practices for Management of Biocontaminated Waste
If the contaminated waste cannot be packaged and transported in accordance with the HMRs due to the
larger volume of waste generated as result of a wide-area incident, a special permit may be necessary.
DOT may grant a special permit if the applicant can demonstrate that an alternative packaging will
achieve a safety level that is at least equal to the safety level required under the HMR or is consistent
with the public interest if a required safety level does not exist. More information on transporting infectious
substances, emergency processing of special permits, and their associated HMR requirements can be
found online at the link below.3
Waste Packaging and Tracking for B. anthracis Incident
B. anthracis-contaminated waste may be stored for further treatment or pending
characterization results in sealed containers that are appropriately labeled. If waste is
temporarily stored before transport to off-site disposal, it must be in containers that meet the
DOT Division 6.2 (Infectious Substances) packaging requirements and follow DOT HMRs. The
storage area should provide weather protection and prevent access by unauthorized individuals
or vermin. Items containing hazardous materials (e.g., asbestos) or radioactive materials
contaminated by B. anthracis spores create additional considerations, as the waste in these
items is more difficult to handle and appropriate precautions are required for their disposal
(Raber et al., 2011). Again, the appropriate state authorities must be consulted to establish
proper waste management procedures for unique waste streams.
The following recommendations are provided to maximize the efficiency of biocontaminated waste
handling operations while minimizing exposure to the personnel involved in the process:
Best practices to minimize exposure
• Correctly don and use/wear appropriate PPE for all steps. Apply caution when removing PPE.
Taking off PPE appropriately is important (i.e., to avoid self-inoculation).
• Triple-package waste in: 1) primary watertight receptacle, 2) watertight secondary packaging,
and 3) rigid outer packaging.
• Place sharps waste in an authorized sharps container, and close and seal it in accordance with
the packaging instructions for that container.
• Once items are in the first bag, close the plastic film bag by tying the bag with a knot or other
equally effective positive means of closure that will not tear or puncture the outer bag or liner
(such as heat sealing, tape, or adhesive) and will ensure any liquid contents will not leak from
the packaging.
• Disinfect the exterior surface of the plastic bag with an appropriate (i.e., EPA approved) agent.
• Place the first plastic film bag, with the knot facing upward, into a second plastic film bag and
close the plastic film bag as previously described for the first bag, making sure the primary bag
does not interfere with closing the second bag.
• Disinfect the exterior surface of the plastic bag with an appropriate (i.e., EPA approved) agent.
3 DOT Pipeline and Hazardous Materials Safety Administration (PHMSA) Transporting Infectious Substances Available online:
http://phmsa.dot.aov/hazmat/transporting-infectious-substances (accessed 4/19/2016).
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Best Practices for Management of Biocontaminated Waste
T • Place in an outer package made of rigid UN standard or DO f-approved non-bulk packaging (if 1
I the outer packaging is fabricated from fiberboard, it must be a minimum of triple wall and I
| contain a 6-mil polyethylene plastic liner) with a maximum capacity of 55 gallons. \
I o Place absorbent material sufficient to absorb all free liquid (if any) in the bottom of the I
| rigid outer packaging or the liner of the fiberboard outer packaging. \
| o Place the double-bagged waste into the rigid outer packaging or into the outer \
I fiberboard packaging with an installed liner. \
| o Close the liner (if used) either by zip tie or other equally effective means of closure or \
I as specified by the manufacturer of the packaging. \
| o Securely close the outer packaging as specified by the manufacturer of the packaging. \
\ • For packaging of larger items, enclose the item in two layers of plastic sheet meeting the \
I following requirements: I
I o All sheets must be marked and certified by the manufacturer as having passed tests \
I prescribed for tear and impact resistance (American Society for Testing and Materials I
| [ASTM] D 1922 and 1709, respectively). \
I o Seal article in first sheet with the openings twisted closed; all seams should be sealed I
I with at least two wraps of duct tape and all other openings with at least two wraps of I
I duct tape or two zip-ties to ensure closure of the wrap; disinfect the exterior surface \
! with an appropriate (i.e., EPA-approved) agent. I
| o Enclose wrapped article in second sheet and seal as previously described. \
I o Package as per appropriate regulations, according to DOT HMRs or special permit. I
I • Disinfect the exterior surface of the package with an appropriate (i.e., EPA-approved) agent. \
I • Mark and label the package in accordance with DOT HMR, 49 CFR Part 172.301. I
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Best Practices for Management of Biocontaminated Waste
8 1 [ n [ I > <1 I I; 1ION/CONTAINI-U 111 1 ^ 1 • <1
Large quantities of liquid waste and wastewater (e.g., from decontamination processes and from washing
down equipment, materials, and personnel) should be managed by collection and treatment when
possible to prevent release into a drainage system and ultimately into nearby rivers or other surface
water. Preventing contaminated wastewater from running off into uncontaminated areas is an important
consideration. The pathways that stormwater runoff take vary greatly from city to city. Vast networks of
storm and sewer drainage systems should be understood to identify places prone to problems such as
overflow and interference with proper wastewater management. Compliance with regulatory restrictions
on wastewater can pose substantial challenges to the management of contaminated liquids. It is
important to consult with the proper regulatory authorities during pre-incident planning activities and
document information in the pre-incident plan so that wastewater can be managed properly.
This prior planning will also help to reduce the number of decisions that need to be made during the
incident response, thereby freeing up the IC/UC to address other important issues associated with the
overall response. The location of drains and other connections that would provide routes for materials to
enter the environment must be identified and exits protected. All chemicals should be separated and
contained according to standard environmental, health, and safety regulations.
A traditional wastewater treatment system may not be able to handle wastewater from a biological
contamination incident. For example, many wastewater treatment facilities market their residual sludge for
land application. The presence of a biological agent may preclude the facility from doing this, resulting in
the creation of an additional waste stream requiring treatment and disposal. Because of this, a
wastewater facility may decline to accept wastewater, even if they are capable of managing it, similar to
solid waste and even hazardous waste facilities refusing to accept waste "tainted with the stigma" of
being from a biological incident. Temporary storage of the wastewater may be necessary and could be
addressed as part of pre-planning incident considerations.
8.1 Wastewater Treatment
The potential generation of large volumes of wastewater makes the wastewater treatment plant (WWTP)
an important stakeholder that needs to be involved early during remediation when decontamination
decisions are made (DHS and EPA, 2009).
The location of drains and other connections that would provide routes for materials to enter the
environment must be identified, and appropriate measures to prevent unintended release to the
environment should be taken. If a centralized containment or staging area is established, materials can
be rinsed into a containment area where wastewater may need to be treated, then characterized,
pumped, and properly disposed of. The need for treatment depends on local regulatory agencies, which
should be contacted early in the remediation process (Raber et al., 2011).
For treatment of wastewater, treatment process operational parameters should be selected based on site
specific conditions, including the bioagent involved. The parameters may vary as a function of pH or other
water-quality factors and must be monitored to ensure effective treatment. Numerous substances in a
wastewater matrix can interact with disinfectants; thus, disinfectant concentrations should be monitored
during any wastewater decontamination process. A combination of treatment technologies may be
necessary depending on the situation. For instance, physical removal techniques, such as filtration,
flocculation, or settling may be necessary in addition to chemical treatment.
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Best Practices for Management of Biocontaminated Waste
8.2 Aerosol Containment from Wastewater
Once decontamination wastewater is generated from a site, wastewater utilities may assume that some
biological agent may have entered the sewer system, and appropriate measures should be taken for
protection. Travel times within the collection system and detention times within the treatment plant can be
estimated (although uncertainties in these estimates can vary) to determine when agents, if contained in
the wastewater, may reach certain points in the collection system and different process units in the
treatment plant. More information on protecting workers and the public from exposure to bioagents that
have entered a storm/waste water system along with recent worker safety data, including suggestions
and recommendations to increase worker safety is available (WERF, 2016).
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Best Practices for Management of Biocontaminated Waste
3 BIOWASTE SAMPLING
Throughout the course of the response and recovery effort, sampling activities after a biological incident
will be conducted for multiple purposes, including screening environmental sampling, characterization
environmental sampling, sampling to support decontamination (both environmental sampling and
decontamination verification sampling), clearance environmental sampling, and post-clearance
environmental sampling (long-term monitoring. In addition, sampling would be done to support public
health assessments and actions. Sampling following the initial identification of the contaminating agent is
intended to determine the extent of contamination and the risk for responders and building occupants.
The development of a sampling plan can help to facilitate this process. As much information as possible
should be obtained about the potential agent to be sampled, its physical characteristics, how it was
released, the substrate it may be on, and its form, to ensure that the most appropriate sampling approach
is used (EPA, 2015).
The sampling methods selected depend on the nature of the incident, the suspected agent, the analytical
laboratory capabilities, and potential data uses. An analytical laboratory should be consulted regarding
methods to collect samples from waste; it is outside the purview of this document to discuss specific
methods regarding sampling.4 Discussions with the data end-users as well as the laboratory will ensure
that the most appropriate sampling method is selected and that the sampling event objectives are met.
Before sampling begins, the sampling team should closely coordinate all sampling requirements with the
laboratory performing the analyses, usually the State Public Health Laboratory. For a wide-area biological
incident, the available laboratory analytical capacity may be insufficient to provide for analysis of all of the
samples that are desired to be analyzed. The state regulatory authorities will make the decision about
frequency of waste sampling. Although it may be simple from a decision-making standpoint to require that
every bag and barrel of waste be sampled, the same pools of laboratories will be analyzing the
characterization and clearance samples from the response, and the burden of analyzing waste samples
could potentially impact the remediation timeline.
In general, samples can be collected with surface wipes, vacuum filters, air filters, and liquid reservoirs
and agar plates from air-impacted material, or from bulk solid or liquid materials that have been exposed.
EPA's Environmental Response Laboratory Network (ERLN) has some limited capacity for analyzing
biological environmental samples, and DHS' Integrated Consortium of Laboratory Networks (ICLN) will
most likely manage surge capacity issues for individual networks (New York City DOHMH, 2015). An
overall prioritization scheme will be integral to maintaining an efficient response. The CDC's Laboratory
Response Network (LRN) typically does not accept environmental samples in media beyond what is
normally used for surface or water sampling (e.g., wipes, sponge sticks, HEPA vacuum socks). The LRN
would likely not take a bulk waste sample for analysis; therefore, large items (such as carpet and PPE)
may need to be cut into smaller pieces.
Waste streams will need to be sampled to determine their characteristics and designations for use by
receiving waste management facilities to meet their facility-specific WAC (EPA, 2015). Sampling and
analysis of waste streams also provide additional information to guide Health and Safety plans for
response workers, as well as waste management facility operators, waste haulers, and the general public
(EPA, 2015).
4 More information can be found at the following EPA link: www.epa.gov/sam (Accessed July 18, 2016).
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Best Practices for Management of Biocontaminated Waste
For each sample location and sample type (air, surface, bulk, or water), planners should select a specific
sampling and analysis method. Characterization planners could select from Selected Analytical Methods
(SAMs) for environmental remediation and recovery following homeland security events (EPA, 2016d).
Planners should also seek guidance from authorized laboratories that will carry out sample analysis to
coordinate sampling procedures and volumes (Raber et al., 2011).
The following recommendations are provided to maximize the efficiency of biocontaminated waste
handling operations while minimizing exposure to the personnel involved in the process:
( !
I Best practices to minimize exposure j
| • Correctly don and use/wear appropriate PPE for all steps; j
j • Change gloves between each sample to prevent cross-contamination; j
| • Do not overfill the sample containers; j
j • Place each sample in an unused, self-sealing sterile bag and properly label each bag, then j
| seal the bag; j
j • Clean the outside of the sealed bag with amended sodium hypochlorite solution just prior to j
| leaving the contaminated area; j
j • Place the cleaned sealed bag into another unused self-sealing bag; j
| • Place contaminated items in a biohazard bag; proceed to decontamination area; j
| • Place the sealed sample bag into an appropriate shipping container and transport samples at j
j ambient temperature, unless specified otherwise, to the analytical laboratory; and j
| • Remove all PPE at the site perimeter and properly dispose. j
I -J
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Best Practices for Management of Biocontaminated Waste
10 TRANSPORTATION AND DISPOSAL
Solid waste disposal is typically regulated by the solid waste management division of a state's
environmental protection department. A waste disposal facility voluntarily accepts waste through
contractual arrangement. It is generally easier to dispose of wastes at facilities within the same state in
which the contamination is located, as opposed to another state. However, optimal disposal facilities for
certain waste streams may not be present or may not be adequate in a particular state.
Municipal waste site operators may be reluctant to take material from a biological incident even after it
has been decontaminated thus, Pre-lncident WMPs are essential. It is advisable during the pre-incident
planning phase to identify multiple potential receiving facilities, and discuss the potential for waste coming
to their facility from a biological incident, their WAC, and whether any permit modifications may be
required. Having access to multiple facilities may become necessary during a large scale incident.
Furthermore, a facility may decline to accept the waste, necessitating the need for backup facilities.
Transportation and Disposal for B. anthracis Incident
B. anthracis-contaminated wastes (along with those of some other bioagents) are not regulated
as hazardous wastes under Subtitle C of the Resource Conservation and Recovery Act (RCRA),
but such contaminated wastes should be handled with caution because of the potential for
exposure to an infectious agent. In some states and localities, such contaminated wastes are
considered medical waste or infectious substances with special requirements for handling and
disposal. Therefore, it is essential to contact the state or local regulatory agency early to
determine what requirements apply and what treatment and disposal options are available.
State authorities have the primary responsibility to regulate and oversee management of
wastes that may be contaminated with an infectious agent such as B. anthracis. It is highly
advisable to establish contact in advance of an incident or early in the remediation process with
waste-disposal stakeholders, such as wastewater treatment plant operators and landfill,
incinerator, and sterilization facilities.
The Pre-lncident WMP plan should reflect any state, local, or facility requirements (e.g., decontamination
actions, post-decontamination sampling, and PPE for transportation and disposal facility workers) for
disposal of decontaminated material as municipal waste. During the incident, the specific WMP should
estimate types and amounts of wastes, transportation needs, and costs. It should also describe any
clearance sampling to be done at disposal sites as well as long-term monitoring requirements, if
necessary. The management of the remediation effort must characterize all wastes and manage each
type according to applicable federal, state, and local regulations.
General criteria to consider prior to off-site transport of the waste should include identification of:
• Source of the waste;
• Waste streams;
• Any restricted materials or hazardous waste;
• Volume reduction methods and needs;
• Waste form (solid, liquid, chemical compatibility);
• Types of external containers (drums, bags, boxes) and associated materials and thickness;
• Primary containers (plastic film bags, lined boxes);
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Best Practices for Management of Biocontaminated Waste
• Weight and dimensions of the waste;
• Handling, transporting, and tracking requirements; and
• WAC (New York City DOHMH, 2015).
The following subsections contain recommendations to maximize the efficiency of biocontaminated
waste handling operations while minimizing exposure to the personnel involved in the process.
ndling/Offloading of Waste at Waste Management Facilities
Hazardous waste management facilities should receive hazardous wastes for treatment, storage or
disposal as outlined below (EPA, 2016a):
• Treatment - Using various processes such as incineration or oxidation to alter the character or
composition of hazardous wastes. Some treatment processes enable waste to be recovered and
reused in manufacturing settings, while other treatment processes dramatically reduce the
amount of hazardous waste.
• Storage - Temporarily holding hazardous wastes until they are treated or disposed. Hazardous
waste is commonly stored prior to treatment or disposal and must be stored in containers, tanks,
containment buildings, drip pads, waste piles, or surface impoundments that comply with the
RCRA regulations. The regulatory requirements for these types of storage units are found in title
40 CFR Part 264 for permitted facilities and Part 265 for interim status facilities.
• Disposal - Permanently containing hazardous wastes. The most common type of disposal facility
is a landfill, where hazardous wastes are disposed of in carefully constructed units designed to
protect groundwater and surface water resources.
Prior to shipment of any waste, waste streams will need to be sampled (discussed in Section 9) to
determine their characteristics and designations for use by receiving waste management facilities. This
characterization is important because the owners/operators of these waste management facilities are
permitted by state environmental agencies with facility-specific WAC. Waste generators must complete
facility-specific waste profiles prior to the facility's acceptance of the waste. This information should be
identified in the Pre-lncident WMP.
I l
I I
j Best practices to minimize exposure j
I I
I I
| • An off-site facility should possess: j
I I
I I
| o Space for further segregation or processing; j
I I
I I
j o Designated temporary storage that provides protection and security against weather, pest j
| infestation, and trespasser interference; j
I I
I I
j o Suitable processing capacity; j
I I
| o Appropriate handling and processing equipment; j
I I
I I
| o Safety equipment and protocols; j
I I
I I
j o Adequately trained and skilled personnel; j
I I
| o Procedures for contingencies and emergency shutdowns; and j
I I
I I
| o A confirmed final disposal site (critical for tracking the waste and ensuring final disposal of j
| the treated residue). j
I I
L- I
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Best Practices for Management of Biocontaminated Waste
B. anthracis is a select agent defined under CDC's Select Agent Regulations (9 CFR 121 and 42 CFR
73); therefore, before transporting B. anthracis-contaminated waste to an off-site treatment
facility, CDC Select Agent Program officials need to be contacted to determine special handling
and transportation requirements that apply. It should be noted that Select Agent Regulations do
not apply to waste that is to be incinerated, autoclaved or otherwise treated for ultimate disposal;
these regulations apply only if intentionally recovering the agent from the waste.
After transport, the containers can be stored on site in loading docks or designated storage areas, but the
wastes must remain in the original containers and the containers may not be opened by the exempt
transfer facility. When wastes remain in the containers that they were shipped in and have not reached
the final destination, the wastes continue to be subject to DOT HMRs. Once waste has arrived at its
destination or is handled on site, the wastes are no longer in transit nor subject to DOT'S regulations but
are instead subject to hazardous waste laws. Wastes may remain on the transport vehicle for up to 10
days after arrival at a facility but, once off-loaded from the vehicle, the waste must be moved directly to an
authorized waste management unit. No additional handling of the waste is allowed, meaning no mixing,
pumping, altering of packaging or handling, of wastes that may lead to a discharge can take place at an
exempt transfer facility. The containers must remain intact and cannot be opened at exempt transfer
facilities. If a facility bulks, packages or containerizes hazardous wastes or handles wastes in any manner
other than transferring a packaged or containerized waste from one vehicle to another, a permit will be
required. When wastes arrive at the designated facility, it constitutes completion of the transportation
phase and the facility operator must acknowledge receipt of the wastes by signing a manifest. (California
Environmental Protection Agency (CalEPA) Department of Toxic Control Substances, 2006)
Best practices to minimize exposure
• Do not stack or compress waste in a way that may compromise package integrity when
loading onto vehicles or during transport; improper stacking can also lead to falling/spillage;
• After loading and prior to transportation, the transporter must perform an external visual
inspection of the transport vehicle to determine that it is closed and free of leakage;
• While in transportation, the doors on the motor vehicle or shipping container being used to
transport the material must be closed and locked except when an outer package is being
loaded or unloaded into the vehicle.
• Under the DOT'S HMRs, the transporter must respond to any release from a package that
occurs during transportation..
• Each motor vehicle used must be decontaminated in accordance with applicable federal, state
and local laws.
Permits for facilities approved to accept the waste should cover the types and quantities of waste,
technical requirements, safety and security precautions, operational requirements (e.g., ability to
inactivate B. anthracis spores) prior to treatment, and disposal of the waste. A permitted facility would
need to demonstrate that it can safely manage this waste at all times, and verification of these conditions
should be provided to the appropriate authority for written approval prior to transporting the waste to the
treatment facility. Many waste management facilities may not have these types of biological wastes
identified within their operating permits and would therefore require permit modification. Identifying this
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Best Practices for Management of Biocontaminated Waste
information in Pre-lncident WMPs can prevent the time required for permitting state agencies to review
and approve these modifications, thereby reducing the overall time and cost of the response and recovery
from these types of incidents.
Items that contain hazardous components at environmentally significant levels will require special
handling, even after the removal of ail viable B. anthracis spores and regulations may vary from state to
state, and consider DOT regulations when applicable. Small waste items that are hazardous, by DOT
definition, must be packaged and transported pursuant to DOT HMR49 CFR Parts 100-185. Sterilized
small and large hazardous waste items that are normally recycled and that contain interstitial spaces
should not be recycled but managed as hazardous waste. Large DOT-regulated items may require
placement in DOT-approved bulk containers.
If the contaminated waste cannot be packaged and transported in accordance with the HMR, the waste
transporter may apply for a special permit.
For a B. anthracis incident, once laboratory analysis verifies the reduction or absence of viable
spores, the treated waste may be managed as follows:
Waste that still has viable spores must be packaged, marked, and labeled in
accordance with appropriate DOT HMR (CFR 49 Parts 100 To 185) and managed and
subsequently treated and disposed of in accordance with state requirements at an
appropriate treatment facility. OSHA Bloodborne Pathogens (BBP) standard (29 CFR
1910.1030) packaging requirements may also apply when the material being packaged
for transport contains a BBP or other potential infectious material under the standard.
Waste that meets the clearance criteria may potentially be discharged to a
wastewater treatment facility (subject to considerations in the discussion above) or
may be managed at an authorized solid waste landfill, recycler, or municipal waste
combustor. Treated vehicles may be managed at an authorized vehicle dismantler or
returned to the owner. Waste must be transported by a transporter permitted to haul
these wastes.
Landfills have traditionally been the final disposal option for solid waste and may be
available for managing the material created in the event of a biological threat agent
terrorist attack.
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Best Practices for Management of Biocontaminated Waste
11 CLEARANCE AND RE-OCCUPATION
Clearance is undertaken to verify the efficacy of decontamination, provide the best possible scientific
evidence that a residual biological agent is no longer present at a level that poses unacceptable risk to
human health, and determine whether it is appropriate to release an outdoor area, semi-enclosed
structure, indoor facility, or water system for re-occupancy or reuse (EPA and CDC, 2012). Establishing
clearance goals, along with a strategy for meeting those goals, is an early and essential step in the
overall remediation process. Clearance goals inform all aspects of the remediation process, from
characterization to decontamination through to clearance. The clearance process itself includes the
following major components:
1. Clearance sampling and analysis, potentially including environmental surface sampling, water
sampling, and air sampling;
2. Review of all relevant information in light of the clearance goals, including review of
environmental sampling data, data on any source-reduction activities, and data from monitoring
the decontamination processes, including any biological indicators used in indoor fumigation
verification; and
3. The determination of whether to release a given area, facility, or water/waste water system for
restoration or re-occupancy (New York City DOHMH, 2015).
Clearance for B. anthracis incident
For a B. anthracis incident, regardless of the type of environment contaminated, the EPA and
CDC recommend that "no detection of viable spores" is the best practicable clearance goal (EPA
and CDC, 2012). There may be viable residual spores present below the current sampling and
analytical detection limits. Currently, culture-based analysis is the best widely available method
for determining the presence of viable B. anthracis spores. Appropriate environmental sampling
and decontamination strategies should be selected to achieve the clearance goal. The clearance
strategy may be adjusted based on the incident; the IC/UC will make the final decisions on
remediation approaches (EPA and CDC, 2012).
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Best Practices for Management of Biocontaminated Waste
}: 1 )N< r
The aim of this document is to inform readers on best practices for handling waste that contains (or
contained) biowaste after a biological incident. Waste will originate from all phases of remediation and
includes contaminated indoor and outdoor materials; waste generated from personnel and victims;
vehicle and equipment decontamination waste, and waste generated from packaging and transporting
contaminated materials. These best practices are applicable to a variety of biological agents, and uses B.
anthracis as a focused example when information is available.
As discussed throughout this document, pre-incident waste management planning is essential. By
considering waste management in advance, it becomes much easier to tailor a Pre-lncident WMP to a
specific site or biological incident rather than waiting to make difficult decisions after the incident occurs or
in the middle of the emergency. In recent years, large incidents involving biological/infectious agents have
generated numerous lessons learned that could be applied to wide area biological incidents and
incorporated into pre-incident waste management planning by federal, state and local emergency
planners and managers. As part of a Pre-lncident WMP, training should be conducted and lessons
learned from the exercises should be incorporated back into the plans to maintain constant improvement
and readiness. EPA's ORCR has developed a pre-incident waste management planning process for
creating, updating, and implementing a Pre-lncident WMP for managing waste. Their four-step process is
designed to help communities prepare for waste management needs of an incident, regardless of the
hazard. A pre-incident plan template outline is provided in Table A-1 of Appendix A.
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Best Practices for Management of Biocontaminated Waste
13 REFERENCES
American Veterinary Medical Association (AVMA); Emergency Preparedness and Response; American
Veterinary Medical Association: Schaumburg, IL, April, 2012.
Animal and Plant Health Inspection Service (APHIS); 2016 HPAI Preparedness and Response Plan; U.S.
Department of Agriculture: Washington, D.C., January 11, 2016.
Beato, M.; De Benedictis, P., General Rules for Decontamination Following an Outbreak of Avian
Influenza or Newcastle Disease. In Avian Influenza and Newcastle Disease - A Field and Laboratory
Manual, Capua, I.; Alexander, D., Eds. Springer - Verlag Italia: Milan, Italy, 2009; pp 133-150.
California Environmental Protection Agency (CalEPA) Department of Toxic Control Substances;
Managing Hazardous Wastes at Transfer Facilities California Environmental Protection Agency:
Sacramento, CA, October, 2006.
Centers for Disease Control and Prevention (CDC); Select Agents and Toxins List.
http://www.selectagents.gov/SelectAgentsandToxinsList.html Page last updated: August 1, 2014
(accessed 2/24/2016).
Centers for Disease Control and Prevention (CDC); Ebola-Associated Waste Management.
http://www.cdc.aov/vhf/ebola/healthcare-us/cleanina/waste-manaaement.html Page last updated:
February 12, 2015 (accessed 4/20/2016).
Committee on Standards and Policies for Decontaminating Public Facilities Affected by Exposure to
Harmful Biological Agents: How Clean is Safe?; Board on Life Sciences; Division on Earth and Life
Studies; National Research Council, Reopening Public Facilities After a Biological Attack: A Decision
Making Framework. The National Academies Press: Washington, D.C., 2005.
Department of Health and Human Services; Response to a Ricin Incident: Guidelines for Federal, State,
and Local Public Health and Medical Officials-, Department of Health and Human Services: Washington,
D.C., 2006.
Department of Homeland Security (DHS) and U.S. Environmental Protection Agency (EPA) Planning
Guidance for Recovery Following Biological Incidents (DRAFT)] Department of Homeland Security:
Washington, D.C., 2009.
Department of Homeland Security (DHS). Denver UASI All-Hazards Regional Recovery Framework,
Version 1.1. October 31, 2012. Available at: http://www.warrp.org/Recovery%20Framework-WARRP-
Aug%2029-2012.pdf (accessed 7/18/16).
Department of Homeland Security (DHS); National Response Framework: Emergency Support Function
#10 - Oil and Hazardous Materials Response Annex; Department of Homeland Security: Washington,
D.C., January, 2008a.
Department of Homeland Security (DHS); National Response Framework: Biological Incident Annex]
Department of Homeland Security: Washington, D.C., August, 2008b.
Department of Homeland Security (DHS); National Response Framework: Food and Agriculture Incident
Annex] Department of Homeland Security: Washington, D.C., August, 2008c.
Department of Homeland Security (DHS); National Incident Management System. Department of
Homeland Security: Washington, D.C., December 2008d. Available at:
http://www.fema.gov/pdf/emergency/nims/NIMS_core.pdf (accessed 7/18/16).
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Best Practices for Management of Biocontaminated Waste
Esworthy, R.; Schierow, L. J.; Copeland, C.; Luther, L. Cleanup after Hurricane Katrina: Environmental
Considerations; Order Code RL33115; Congressional Research Service - Library of Congress:
Washington, D.C., 2005.
Government Accountability Office (GAO); Capitol Hill Anthrax Incident: EPA's Cleanup was Successful;
Opportunities Exist to Enhance Contract Oversight; GAO-03-686 Government Accounting Office:
Washington, D.C., June, 2003.
Guidelines for Mass Casualty Decontamination During a HAZMAT/Weapon of Mass Destruction Incident,
Volumes I and II (ECBC-SP-024), U.S. Army Chemical Biological, Radiological and Nuclear School,
August 2013; Lake, William; Divarco, Stephen; Schulze, Peter; Gougelet, Robert.
Knowlton, R. G.; Melton, B. J.; Einfeld, W.; Tucker, M. D.; Franco, D. O.; Yang, L. I. Quick Start User's
Guide for the PATH/AWARE Decision Support System; SAND2012-9466; Sandia National Laboratories:
Albuquerque, NM, June, 2013.
Minnesota Board of Animal Health; Disposal of Poultry Carcasses: Highly Pathogenic Avian Influenza;
Minnesota Board of Animal Health: St Paul, MN, May 7, 2015.
National Alliance of State Animal and Agricultural Emergency Programs (NASAAEP) Best Practices
Working Group; Emergency Animal Decontamination Best Practices; National Alliance of State Animal
and Agricultural Emergency Programs: Albany, NY, September, 2014.
National Infrastructure Simulation and Analysis Center (NISAC); Instant Situational Awareness Using
FASTMap. http://www.sandia.gov/nisac/analvses/fast-analvsis-and-simulation-team-fast/ (accessed
2/23/2016).
National Science and Technology Council (NSTC). Biological Response and Recovery Science and
Technology Working Group. Biological Response and Recovery Science and Technology Roadmap.
October, 2013.
https://www.whitehouse.gov/sites/default/files/microsites/ostp/NSTC/brrst_roadmap_2013.pdf (accessed
7/15/2016)
New York City Department of Environmental Health; New York City Department of Health and Mental
Environmental Response and Remediation Plan for Biological Incidents (DRAFT)] New York City
Department of Environmental Health: New York City, NY, February 25, 2015.
Occupational Safety and Health Administration (OSHA); Anthrax eTool.
https://www.osha.gov/SLTC/etools/anthrax/decon.html (accessed 01/28/2016).
Occupational Safety and Health Administration (OSHA); Fact Sheet: Safe Handling, Treatment,
Transport, and Disposal of Ebola-Contaminated Waste] DTSEM FS-3766; Occupational Safety and
Health Administration: Washington, D.C., March, 2016. https://osha.gov/Publications/OSHA_FS-3766.pdf
(accessed 7/18/16).
Okumura T, Kondo H, Nagayama H, Makino T, Yoshioka T, Yamamoto Y. Simple triage and rapid
decontamination of mass casualties with the colored clothes pegs (STARDOM-CCP) system against
chemical releases. Prehosp Disaster Med. 2007;22:233-6.
Raber, E.; Kirvel, R.; MacQueen, D.; Love, A.; Dombroski, M.; McGrann, T.; Richards, J.; Melius, C.;
Bunt, T.; Hibbard, W.; Greenwalt, R.; Miles, R.; Dillon, M.; Mancieri, S.; Harris, S.; Michalik, R.; Wheeler,
R.; Hoppes, B.; Tucker, M.; Krauter, P.; Knowlton, R.; Yang, L.; Franco, D.; Einfeld, W.; Brockman, J.;
Betty, R. Interim Consequence Management Guidance for a Wide-Area Biological Attack] LLNL-TR-
484706; Lawrence Livermore National Laboratory: Livermore, CA, May 11, 2011.
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Best Practices for Management of Biocontaminated Waste
Simpson, M. Anthrax-Contaminated Facilities: Preparations and a Standard for Remediation-,
Congressional Research Service: Library of Congress, 2005.
U.S. Environmental Protection Agency (EPA) and Centers for Disease Control and Prevention (CDC);
Interim Clearance Strategy for Environments Contaminated with Bacillus anthracis; U.S. Environmental
Protection Agency: Washington, D.C., July, 2012.
U.S. Environmental Protection Agency (EPA); Disposal of Domestic Birds Infected by Avian Influenza- An
Overview of Considerations and Options; U.S. Environmental Protection Agency: Washington, D.C.,
2006.
U.S. Environmental Protection Agency (EPA); WARRP Waste Management Workshop; U.S.
Environmental Protection Agency: Washington, D.C., November 13, 2012.
U.S. Environmental Protection Agency (EPA); Bio-Response Operational Testing and Evaluation (BOTE)
Project Phase 1: Decontamination Assessment; EPA-600-R-13-168; U.S. Environmental Protection
Agency: Washington, D.C., 29 November, 2013.
U.S. Environmental Protection Agency (EPA); Comprehensive Biological Tactical Guidebook, Version
1.0; U.S. Environmental Protection Agency: Washington, D.C., August, 2015.
U.S. Environmental Protection Agency (EPA); Hazardous Waste Management Facilities and Hazardous
Waste Management Units, https://www.epa.gov/hwpermittinq/hazardous-waste-manaqement-facilities-
and-hazardous-waste-manaqement-units Page last updated: February 5, 2016a (accessed 4/20/2016).
U.S. Environmental Protection Agency (EPA); Managing Materials and Wastes for Homeland Security
Incidents, https://www.epa.gov/homeland-securitv-waste Page last updated: Last updated on April 8,
2016b (accessed 4/20/2016).
U.S. Environmental Protection Agency (EPA); Vehicle Decontamination Line - Quick Reference Guide for
a Biological Response] U.S. Environmental Protection Agency Emergency Response Technical Group:
Washington, D.C., 2016c.
U.S. Environmental Protection Agency (EPA); Selected Analytical Methods for Environmental
Remediation and Recovery (SAM) - Home; https://www.epa.gov/homeland-security-research/sam Page
last updated: April 14, 2016d (accessed 7/15/2016).
United States. Executive Office of the President and Assistant to the President for Homeland Security and
Counterterrorism; The Federal Response to Hurricane Katrina: Lessons Learned; The White House:
Washington DC, 2006.
Water Environment Research Foundation (WERF); Collaborative Workshop on Handling, Management,
and Treatment of Bio-Contaminated Wastewater by Water Resource Recovery Facilities; Water
Environment Research Foundation: Alexandria, VA, 2016.
World Health Organization (WHO); Ebola Virus Disease.
http://www.who.int/mediacentre/factsheets/fs103/en/ (accessed 4/20/2016).
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APPENDIX A
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Best Practices for Management of Biocontaminated Waste
Am:';NDI * .'-JHivl II •¦ilMiVlll lil <.»! 11 fE PRE-IH'MI-h NI
MANAGEMENT PLAIN (WIMP)
This Appendix describes the recommended pre-incident waste management planning process for
creating, updating, and implementing a Pre-lncident WMP for managing biological wastes. As depicted in
Figure 3 of Section 4, the waste management planning process can be divided into four main steps:
1) Conducting pre-planning activities;
2) Developing a comprehensive Pre-lncident WMP for all hazards;
3) Keeping the WMP updated by regularly reviewing, maintaining, exercising, and training with the
WMP; and
4) Implementing the WMP during an incident.
The components of these steps are described in the following sections. A pre-incident plan template
outline is provided in Table A-1.
Step ^-Planning Activities
1) Prioritize plan development:
o Conduct a hazard assessment, looking at possible scenarios and hazards, their
likelihood, and the wastes and volumes generated.
o Consider whether you want a single plan that addresses all hazards (recommended) or
separate, scenario-specific plans.
2) Identify and engage individuals who should be involved in the planning process for possible
scenarios or scenario-specific plans, as appropriate;
3) Identify and review national, regional, and local plans, any industry-specific plans, and mutual aid
agreements (MAAs), if appropriate:
o Include plans of bordering localities, if appropriate.
4) Identify opportunities for hazard mitigation to enhance community resilience (e.g., retrofit PCB
transformers);
5) Determine legal and regulatory waste management requirements, issues, and considerations;
6) Determine FEMA cost reimbursement requirements, if appropriate; and
7) Identify unique local circumstances/issues (e.g., union issues, geography).
Step 21 Pre-lncident W
1) Use available tools to aid in the plan development;
2) Consult with the individuals identified in Step 1 when developing the plan;
3) Consult with owners and operators of waste management facilities, haulers, and other entities as
they are identified while developing the plan; and
4) Identify options for reuse and recycling for different wastes and consult with facilities about
establishing acceptance criteria for those wastes.
A-2
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Best Practices for Management of Biocontaminated Waste
Step 3: Willi' I < /iew, Maintenance, Exercise, at><' 11 lining
1) Meet with stakeholders to review and update the Pre-lncident WMP regularly;
2) Schedule waste management-related exercises;
3) Develop a training plan to address training needs (for staff and equipment); and
4) Incorporate any waste management lessons learned, after action reports, and improvement plans
into the Pre-lncident WMP.
Step 4: Incident-Specific WHIP
1) Identify the Pre-lncident WMP that best aligns to the specific incident;
2) Identify waste management-related policy or implementation issues that require resolution;
3) Create the incident-specific WMP based on the Pre-lncident WMP:
o Include the incident's situational overview, generated waste types and quantities,
locations of waste, an exit strategy, and health and safety requirements and update other
sections of the plan with real world numbers, as appropriate.
4) Present the incident-specific plan to the appropriate IC staff;
5) Notify waste management facilities of anticipated needs and exercise contract support where
necessary;
6) Implement the community communications/outreach plan;
7) Identify sampling requirements and notify laboratories of anticipated analysis needs;
8) Conduct waste management oversight activities (e.g., site visits and inspections of, as well as
environmental monitoring at, waste management sites, contractors), as necessary; and
9) Implement the cradle-to-grave waste and material tracking and reporting system.
The outline in Table A-1 describes the "table of contents" of a typical Pre-lncident WMP. The column on
the left specifies the information to be included in a WMP, while the column on the right describes various
issues that should be considered when developing each section of the plan to maximize its benefit during
an actual incident. This column also provides links to tools and resources that may aid in the development
of the plan, as well as tips on adapting the plan to an incident-specific plan after an actual incident occurs.
The plan contents and list of considerations are not exhaustive and are not intended to be prescriptive.
Instead, this outline is intended to be a starting point to aid in the development of a Pre-lncident WMP.
The final organization and contents of a WMP are entirely up to emergency managers and planners.
Keep in mind that the National Response Framework (NRF) will guide a response through an incident
and thus should be considered when developing a plan.
This outline assumes an all hazards Pre-lncident WMP. Much of the information in a WMP is applicable to
any scenario. Text in red, indicates information that will be replaced or updated at the time of the incident.
However, scenario- and agent-specific information also should be developed to the extent possible and
included in an all hazards plan. This information may be incorporated as additional sub-headings within
each section or as a series of appendices to the WMP.
A-3
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Best Practices for Management of Biocontaminated Waste
lalbll ggested IPre-llincident All Hazards Waste Management Plain Outline
1. Plan Overview
1. Scope
Scenario and entity covered
2. Planning assumptions
3. List of officials who should be notified in the
case of an incident
4. Regulatory requirements
5. Record of plan reviews and updates
(e.g., adding new and updating current
facilities)
This section will be replaced at time of incident with
the Situational Overview.
Scenarios may be based on National Planning
Scenarios and/or site-/community-specific threats
or hazards.
Include relevant federal, state, tribal, local, and
territorial regulatory and legal requirements that
impact waste management, as well as the impact
that an emergency declaration might have on
applicable laws. Keep in mind that state
requirements may be more stringent than federal
requirements and may include additional waste
streams not covered under federal laws.
II. Materials and Waste Streams
1. List of anticipated waste streams
2. Description of each waste stream
Include regulatory status (federal and state),
associated hazards if any, agent-specific (e.g.,
biological) information, fact sheets if any, and
packaging, labeling, handling, and
transportation requirements, as well as identify
decontamination and reuse, recycling,
treatment, and disposal options appropriate to
that waste stream
This section will be replaced at time of incident with
the actual waste streams generated by the
incident.
III. Waste Quantities
1. Forecast quantity of each type of anticipated
waste
2. Method for estimating actual waste quantities
during/after incident
(e.g., GIS, windshield assessment)
This section will be replaced at time of incident with
waste estimates based on the specifics of the
incident.
Recommended tools:
Incident Waste Decision Support Tool
(I-WASTE DST) Accessed May 20, 2016, at
htto://www2.eraweb.com/bdrtool/loain.asD
Hazus (FEMA's tool for estimating potential losses
from disasters) Accessed May 20, 2016, at
http://www.fema.aov/hazus
IV. Waste Characterization Sampling and Analysis
(for each waste stream)
1. Sampling
Two different types of sampling may be needed to
meet WAC at waste management facilities and to
allay community concerns: 1) sampling to
A-4
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Best Practices for Management of Biocontaminated Waste
IPIIsin Contents:
Estimate number of samples, identify type of
analysis needed for each waste/material type,
and address health and safety issues, such as
appropriate PPE for sampling activities
2. Analysis
Identify laboratories that can conduct the
analyses, as well as methodologies for the
analyses, what items are needed for sampling
(e.g., swabs, sample bottles), sampling
methodologies (e.g., composite sampling
procedures), and the required techniques
3. Quality assurance
Identify methods that will be used to ensure
quality assurance
V. Waste Management Strategies/Options
1. General principles
by activity
a. Minimization (actions to minimize waste
generation, toxicity, physical size)
b. Collection (procedures; health and safety
requirements)
c. Segregation (procedures)
d. Decontamination (people, equipment,
waste/materials; health and safety
requirements)
e. Accumulation/Storage (site location
selection criteria; documentation; health
and safety requirements)
2. Pre-selected waste management sites
Site-specific information, by category
a. Waste staging and storage (temporary and
permanent) locations
b. Equipment staging and storage (temporary
and permanent) locations
c. Decontamination stations
Considerations:
determine federal, state, or local regulatory status,
and 2) sampling to ensure that waste/materials
have been effectively decontaminated.
Environmental Justice and other community
concerns may make it advisable to conduct testing
even when it is not regulatorily required or conduct
additional sampling and analysis to ensure
transparency. As this additional testing may be
cost-prohibitive, an alternative may be managing
all waste as hazardous waste under RCRA. The
relative costs/benefits should be evaluated.
Laboratory selection considerations include
capacity, access, cost, time needed to produce
results, and anticipated community concerns.
This section should be updated as needed during
an incident (e.g., with sites that are used or may be
used to manage waste during the incident).
Relevant regulatory and other legal requirements
should be considered.
Reuse and recycling are preferred options;
consider adding a list of possible materials that can
be reused or recycled.
Identify multiple sites/locations to choose from
during an incident, if possible. However,
designating specific sites/locations in advance of
an incident may not be possible. In this case,
develop guidelines that could be used to designate
sites during an incident.
Whether specifying sites/locations or developing
guidelines, consider:
• Benefits of on-site vs. off-site
management;
• Speed with which waste needs to be
managed;
• Facility requirements and capacity;
• Permitting procedures;
• Cost of various options;
• Community/Environmental Justice
concerns;
• Site security;
• Resources needed, including private
sources of equipment;
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• FEMA cost reimbursement requirements;
• Proximity to anticipated waste generation
points;
• Ease of access;
• Ease of containment of wastes/materials;
• Ownership of sites; and
• Proximity to sensitive/protected areas.
Consider possible need for long-term groundwater,
air, and other environmental monitoring at on-site
burial sites and other waste management facilities
or sites.
VI. Waste Management Facilities
1. Anticipated types of waste management
facilities needed
Identify all facility types needed to manage
anticipated waste streams and quantities
2. Specific facilities identified
Detailed information on each potential site, to
aid in selection at time of incident, including
some or all of the following: facility name, type,
contact information for site manager and
support staff, location information (including
latitude/longitude), permit status and
compliance history, types of waste accepted,
pre-negotiated contracts, if any, waste
capacity, WAC, financial status, distance from
anticipated waste generation points, cost,
community concerns
This section should be updated as needed during
an incident with facilities that are used or may be
used to manage waste during the incident.
Identify multiple waste management facilities to
choose from in case an incident occurs. Waste
from wide area incidents may exceed the capacity
of local facilities, or facilities may refuse to accept
the waste. Out-of-state facilities may be necessary.
State permission may be required.
Communicating with facilities before an incident
occurs can help to determine the facilities' WAC,
which may be more stringent than what is legally
required (e.g., to help determine sampling and
analysis needs, size requirements).
VII. Transportation
1. Logistical options
2. Routes (including maps)
3. Hauler information
Detailed information on each potential hauler
to aid in selection at time of incident, including
some or all of the following: hauler's name,
type, contact information, wastes they are
permitted to handle, community concerns,
security and legal requirements,
decontamination needs, insurance
requirements, PPE requirements, any special
documentation requirements, spill response
plan, and pre-negotiated contracts, if
applicable
Consider all modes of transportation, including
vessel and rail, as well as possible differences in
restrictions for interstate highways and local
roads. Keep in mind packaging, labeling, and
transportation requirements (e.g., USDOT, state).
Zoning restrictions may be an issue, particularly
for large vehicles.
State permission may be required.
Highway weight restrictions may vary based on
time of year.
Proximity to transportation is an important
consideration when selecting a waste
management site (e.g., whether heavy equipment
can access the site to load the large quantities of
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waste onto barges, railway), as well as proximity
to waste management facilities.
Consider including a pre-scripted outline or fact
sheet of hauler responsibilities, including health
and safety requirements.
Drivers may be considered emergency workers
and subject to applicable exposure limits.
VIII. Waste and Material Tracking and Reporting
System
1. General principles
2. Databases or other tracking software to be
used
3. Waste tracking report templates
Indicate information to be tracked
Tracking the waste from cradle to grave helps
increase transparency and aids in allaying
community concerns. Keep in mind security
concerns regarding sensitive information.
Haulers may use different units of measurement,
which should be adjusted as needed to maintain
consistency.
IX. Community Communications/Outreach Plan
1. Contact information for key stakeholder groups
(e.g., community groups, government officials)
2. Pre-scripted information for waste
management activities involving the public
(e.g., fact sheets, public service
announcements (PSAs), frequently asked
questions)
3. Information for a response website
Past incidents show that communities express
more concern with wastes from homeland security
incidents than they do with wastes not tied to such
incidents; community concerns have driven waste
management decisions in the past (perceived risk
vs. actual risk).
Community outreach may include detailing special
training, required PPE, and safety information,
especially during a chemical, biological, or
radiological incident, for facility personnel, people
who choose not to evacuate their homes and thus
are living with contamination in their homes, and
responders, including volunteers who are helping
to clean up the waste.
During an actual incident, public outreach takes
place within the Incident Command System.
Also consider the use of social media and the need
for interpreters/translators.
X. Health and Safety for Waste Management Activities
Ensure that the overall incident HASP includes
information related to waste management activities.
While a general HASP for the incident will be
developed, specific waste management activities
may require additional guidance and should be
addressed.
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XI. Resource Summary
Resources may be available in-house, from
Gathered from all previous sections
contracts, or through agreements.
1. Resource needs
Equipment, staff, other
Contractor qualification requirements should be
2. Resource sources
considered.
a. Mutual Aid Agreements (MAAs)
b. Pre-negotiated contracts
3. Specialized Technical Assistance Contacts
4. Contracting
a. Emergency procurement procedures
b. Contract oversight plan
5. Cost Accounting/Financial Management
6. FEMA Cost Reimbursement Forms and
Guidance
XI. Oversight Activities and Exit Strategy
Describe the process for transitioning each waste
management activity back to its pre-incident state,
including the scale-down/close-out of each waste
management response activity (e.g., waste
collection and staging, air monitoring of staging
areas) and each waste management oversight
activity performed (e.g., site visits/inspections of
waste management facilities and sites, sampling
and analysis of waste streams), the transition of
roles and responsibilities, and the frequency of
each activity.
This section will be developed and added at the
time of an incident.
It is important to note that there may be some
waste management activities that extend beyond
the end of the response that should be addressed
in the exit strategy (e.g., long-term monitoring).
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