Hello Daniel my question is when transporting regulated medical waste what is the proper manifest to use
Thank you for your attention to my question.
It took me a few weeks to reply (I replied 05.10.17). I was real busy back then:
Thank you for contacting me. I apologize for the delay in my response. Please see below.
The answer to your questions depends on whether or not the regulated medical waste is subject to the Hazardous Materials Regulations of the USDOT. It may be subject to an exception from full regulation. Please read: The Identification and Transportation of a Regulated Medical Waste.
Also, since regulated medical waste is not regulated by the USEPA it may be subject to state-specific regulations. Some states require the use of a state-specific shipping document for regulated medical waste, e.g. Potentially Infectious Medical Waste in Illinois.
I hope this helps. Please don’t hesitate to contact me with any other questions.
Interested in site specific training at your site that covers this topic, and more!
I RECEIVED A QUESTION FROM A COMPANY WITH WHICH I’VE HAD A LONG AND FULFILLING RELATIONSHIP. I WAS GLAD TO HELP WHEN I RECEIVED THIS EMAIL ON APRIL 22ND:
Hello Dan. I hope everything is going well for you.
Have you ever ran into a infectious waste that is potentially flammable too? The generator can’t even find a lab to test it and the question has come up about both EPA waste designation and DOT. Does infectious waste take precedence and you don’t need to consider the flammability for either DOT or RCRA? Just asking if you knew something off the top, don’t need to investigate.
I DID HAVE SOMETHING OFF THE TOP – AND DID A LITTLE INVESTIGATING TOO – TO DELIVER BACK AN ANSWER THAT SAME DAY:
USEPA does not regulate Medical Waste. Illinois EPA does however, as a Potentially Infectious Medical Waste. USDOT regulates as an Infectious Substance when in transportation. OSHA regulates as a BioHazard when worker exposure is a concern.
A generator is required to make a hazardous waste determination for all waste, therefore they must determine if D001 applies. If testing is not possible, they can make determination based on generator knowledge.
A separate determination is made when offered for transportation as a hazardous material per USDOT. There it will likely be a Class 3 Flammable Liquid, a USEPA hazardous waste (depending on generator status), and a Division 6.2 Infectious Substance.
Please let me know if you have any other questions.
HIS REPLY JUST A FEW MINUTES LATER:
Thank you Dan.
Have a great day,.
AND THAT WAS IT. THE ENTIRE Q&A COMPLETED IN A FEW HOURS OF AN AFTERNOON. I CAN BE JUST AS QUICK ANSWERING YOUR QUESTIONS, SO DON’T HESITATE TO ASK ME.
Contact me with any questions you may have about the generation, identification, management, and disposal of hazardous waste
Healthcare facilities may generate a variety of wastes, though due to the nature of their operations, these waste may fall into one of several common categories. Each of these wastes will require special on-site handling and off-site disposal depending on their characteristics and the applicable regulations of the USEPA or a state with an authorized hazardous waste program. In addition to state or federal hazardous waste regulations, these wastes will also be subject to the Hazardous Material Regulations (HMR) of the PHMSA/USDOT when transported or offered for transportation. In either case it is the responsibility if the generator of the waste and/or the shipper of the hazardous material to make the proper classification and comply with the applicable regulations.
Common healthcare waste are identified below:
Laboratories
Staining lines
Formalin
Test Kits
pH Adjusters
Reagents
Solvents like: Xylene & Isopropyl Alcohol
Ictotest/Clinitest/Acetest Tablets
Facilities
Solvent-Based Paint
Aerosols (spray paint, cleaners, solvents)
Paint Thinners & Solvents
Water Treatment Chemicals for Boiler
Oils (lubricant, hydraulic, cooling)
X-ray Machines
Lead Aprons
Nursing
Cleaners
EKG Leads
Hand Sanitizers
Universal Waste
Batteries
Fluorescent Lamps
Mercury-Containing Devices
e-Waste (in some states)
You may also generate a waste that is not regulated by USEPA or your state under the Resource Conservation and Recovery Act (RCRA) but may be regulated in transportation by the PHMSA/USDOT as an Infectious Substance (Hazard Division 6.2). Please read this article regarding the Exception for the Transportation of Regulated Medical Waste to ensure compliance.
The Hazardous Material Regulations (HMR) of the PHMSA/USDOT regulate the transportation in commerce of an Infectious Substance (Hazard Class 6, Division 6.2). The description of Division 6.2 at 49 CFR 173.134 includes a definition of both Regulated Medical Waste and Sharps, and an exception from full regulation under the HMR for Regulated Medical Waste if shipped as required. The purpose of this article is to explain the requirements to comply with the exception for transportation of a Regulated Medical Waste. (more…)
