Who is Maintaining Your Medical Waste?

Last updated on May 7, 2021

This is an update of the article originally published on August 6, 2014. Regulations change frequently. That’s why Sharps Compliance monitors updates and communicates any changes to its customers.

“I don’t have time to close up and label the medical waste box – so the medical waste transport driver does it.”

This statement is often uttered by busy employees responsible for managing their facility’s medical waste. However, the US Department of Transportation (DOT) and other regulatory bodies place the onus of responsibility for preparing and packaging medical waste on the generator of the waste, not the transporter.

The DOT and individual states regulate transport and labeling of waste managed by a pickup service. Since the facility that generates this waste is responsible for the proper packaging, the DOT requires anyone who “prepares medical waste for transport” to be trained in the proper procedure. Training must be documented and repeated every three years. In addition, states can require training as well.

When mailing medical waste, instructions are included with each mailback system, which can be used for training on proper packaging. DOT does not regulate mailback packages and therefore, does not require the training mandated by DOT. However, since the person packaging the waste is still responsible for properly doing so, it is important to train the employee using the mailback instructions.

When signing the manifest tracking form that must follow the waste from “cradle to grave,” the person signing the form declares that the contents have been classified, packaged, marked, and labeled according to applicable government regulations. This is true for both pickup service and mailback. That person declares that the shipment does not include hazardous materials, such as mercury or hazardous drugs. For this reason, only employees of the generator can close or and package the transport or shipping box and sign the manifest tracking form.

If your organization is using a pickup service, follow the driver’s instructions, which typically include the following:

• Build out the box, making sure the box bottom is taped well, and all closure and/or locking mechanisms are engaged and taped closed.
• Place liner in the box.
• Close sharps containers and tie up red bags before placing into lined box or container.
• Securely tie closed liner around containers/bags.
• Close the box flaps and secure with packing tape or secure the lid and closures.
• Place label(s) as required by state regulations, including the label provided by the medical waste company.
• Sign manifest tracking form (keep generator copy).
• Provide box/container to pickup driver.
• Access proof of treatment.

If you are using a mailback system, written instructions are included with each system. Instructions include the following:

• Retain plastic-lined mailback box to ship container(s) back for treatment.
• Close sharps containers and tie up red bags prior to placing into lined box/container.
• Absorbent is already included in liner and/or each sharps container.
• Securely seal liner around filled container(s) using provided twist or zip tie.
• Close the numbered box flaps and place provided tape over closure tab(s).
• Write the facility return address on the top of the box. No additional labeling is required.
• Complete and sign manifest tracking form (keep generator copy).
• Provide to mail carrier.
• Access proof of treatment.

Don’t get caught out of compliance! Our ComplianceTrac tool helps offices build plans and policies to address these issues.