Between downward pressures on reimbursement and rising costs, managing a medical practice can be difficult enough without staying up nights wondering what will happen if an OSHA inspector shows up at your door.
If your staff isn't current on the latest regulations, or if new employees don't understand the different types of medical wastes and how they should be handled, what they don't know could cost you. In fact, each non-compliant item on an OSHA checklist could carry a fine of up to $7,000.
So how do you make sure wastes are handled properly and get that worry off your mind?
"Everyone who works in a healthcare facility should be knowledgeable of the different types of regulated waste streams that are generated there, and understand the correct management procedures and proper accumulation containers to use," John P. Fulkerson of Environmental Biological Services (EBS) said. "When people think about medical waste, they usually think about red biohazard bags or accumulation containers. But not everything is necessarily a red bag disposal solution.
"For example, when removing paper from an exam table, if blood or body fluids are present or if a patient with a potentially infectious condition has come into contact with it, then it should go into a red bag. But if you put all paper from exams in a red bag, you could be filling more of them than necessary. You can characterize paper from a well-patient exam or where no OPIM exists as normal solid waste and reduce the volume of more costly biohazard materials you are generating."
Administrators should also handle expired or partially used pharmaceuticals with care. Aquifers that supply drinking water to major metropolitan areas are already showing traces of prescription drugs. Especially in an age of antibiotic-resistant superbugs, pharmaceuticals should not end up in landfills where ground water can run off into rivers, and they should not be flushed down toilets where they could remain in the ecosystem indefinitely.
"If your facility accumulates quantities of expired or partially-used pharmaceuticals that need disposal, you can check with the original manufacturers or vendors. Some of them have return policies that might save you money on disposal of those products. Otherwise, unused or expired pharmaceuticals should go in an alternate colored container based on their classification," Fulkerson said. "Pharmaceuticals are probably the most misunderstood stream of medical waste generated. Fortunately, the EPA is currently reviewing pharmaceutical waste guidelines, and there is an addendum under consideration that should help to simplify categorization, handling and disposal of this type of waste. We're hoping to see more concrete clarity in that area in the next 12 to 24 months."
What is the most common problem Fulkerson sees when he visits facilities to do an inspection-readiness audit?
"Sharps accumulation," Fulkerson said. "Overfilling sharps containers is more common than you might imagine. On every disposable sharps container is a manufacturer's recommended fill line that is at about the three-quarter mark. We often see that sharps continue to accumulate well past the fill line until containers are nearly overflowing. Letting it get to that point makes it more likely that you could get a stick with something you don't want to come into contact with your skin. When sharps are at the manufacturer's maximum fill line, the container should be closed, locked and sealed; then put in a medical waste container for your disposal company to pick up."
In addition to medical waste disposal, Fulkerson says that EBS offers annual on-site training for their clients' staff and a walk-through audit of the premises to check for potentially noncompliant situations that need to be corrected before the next OSHA inspection.
"Medical waste streams are regulated by multiple government entities, including environmental, occupational health and safety, and the US Department of Transportation," Fulkerson said. "There are frequent changes. Even veteran administrators feel more assured knowing they are up to date on the latest requirements. New employees should also be brought up to speed upon initial hire as well as annually. All healthcare workers should be taught how to identify and manage the different streams of medical waste your facility generates and how to segregate and package them for pickup so they can be disposed of properly."
"In addition to on-site training and audit services like we offer, the Alabama Department of Environmental Management is an excellent informational resource for healthcare providers," Fulkerson said.
Looking at the big picture, managing medical waste isn't just about regulations. It's about keeping yourself, your employees, your patients and the public safe and healthy.