Regulated Medical Waste Disposal Procedures

by Matthew Domser, Senior Hazardous Materials Manager

Regulated medical waste (RWM) or “red bag” waste is generated when labs and clinics on campus collect biologically contaminated materials for disposal. This waste requires more rigorous disposal management since it is defined as “Regulated Waste” under OSHA’s Blood Borne Pathogens Standard [29 CFR 1910.1030(b)]. The definition includes “contaminated items that would release blood or other potentially infectious materials (OPIM) in a liquid or semi-liquid state if compressed” and “pathological and microbiological wastes containing blood or other OPIM” to be considered red bag waste. On the WCM campus, this includes materials used in infectious protocols, such as BSL-2 & BSL-3 lab spaces, as well as grossly contaminated PPE (i.e., blood-soaked gloves, gowns, masks, etc.). Not all PPE or other materials used in biological protocols or clinical procedures are necessarily considered red bag waste. If the materials do not meet the OSHA definition as explained above, then this waste could be discarded in regular trash or municipal disposal.

Between 2020 and 2022, the number of principal investigators (PIs) on campus increased by 7% (~20 researchers). However, there has been a 14% increase in red bag waste during this same time period. This percentage represents about 26,000 lbs., suggesting that regular trash is being commingled in red bag wastes.  These mixed materials can present additional exposure hazards to housekeeping personnel and add significant disposal costs to the college.

EHS is launching an initiative to develop a one-page biological waste guide for researchers and clinicians that will help quickly assess how to properly dispose of items used during biological and clinical procedures. In addition, these will be released with guides that clarify chemical, electronic, and municipal disposal.

Are BSL-1 materials considered red bag wastes?

If these wastes have been inactivated, they are considered regular trash.  Most inactivation can be accomplished with 10% bleach and appropriate contact time or washing with soap and water (in the case of PPE, such as gloves). PPE that was not exposed to your working materials would be considered trash.

How does a material meet the definition of regulated waste?

It is considered red bag waste if it drips or releases blood or other potentially infectious materials when compressed. For example, consider a saturated, bloody gauze vs. a used band-aid from a minor laceration. The gauze would be considered a regulated material and require red bag disposal. The band-aid, while likely to contain some blood from the cut, would be able to retain the liquid volume without releasing it. This band-aid would be regular trash.

Is PPE contaminated with chemicals suitable to dispose of in a red bag? What about small amounts of chemicals?

No, and no. If PPE is exposed to acute toxics or HHOPs, it should be collected separately and submitted as chemical waste for pickup by EHS. Chemicals should always be collected and submitted to EHS for removal via Salute. Some biological liquids, <10mL, are acceptable for red bag disposal if properly contained.

Is all PPE used in clinical procedures considered red bag waste?

No. Most PPE from routine and non-emergency procedures are acceptable to place in regular trash. However, bloodied gloves, masks, gowns, etc., would be considered red bag waste.

waste

Example of materials suitable for trash disposal found in red bag waste

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Chemical kits improperly disposed in red bag waste



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