Medical Waste Management FAQs

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• What qualifies as medical waste?

  The full definition for medical waste can be found in CA HSC 117690.  In summary, “Medical waste” means any biohazardous, pathology, pharmaceutical, or trace chemotherapy waste not regulated by the federal Resource Conservation and Recovery Act of 1976; sharps and trace chemotherapy wastes generated in a health care setting in the diagnosis, treatment, immunization, or care of humans or animals; waste generated in autopsy or necropsy; waste generated during preparation of a body for final disposition such as cremation or interment; waste generated in research pertaining to the production or testing of microbiologicals; waste generated in research using human or animal pathogens; sharps and laboratory waste that poses a potential risk of infection to humans generated in the inoculation of animals in commercial farming operations; waste generated from the consolidation of home-generated sharps; and waste generated in the cleanup of trauma scenes. 

• Does medical waste have to be managed into a red bag?

  In the State of California, a biohazard bag (A.K.A. “red bag”) is a disposable film bag used to contain medical waste.  It is also required to be red, except when yellow bags are used to further segregate trace chemotherapy waste and white bags are used to further segregate pathology waste. The biohazard bag shall be marked with the international biohazard symbol and may be labeled by reference as authorized by the US Department of Transportation. HSC 117630

• Are animal carcasses medical waste and how do you manage it?

  Animal carcasses are medical waste (as pathology waste) if it “is suspected by the attending veterinarian of being infected with a pathogen that is also infectious to humans”. HSC 117690

  Management of Deceased animals: Pathology waste

  Pathology waste, as defined in paragraph (2) of subdivision (b) of Section 117690, shall be segregated for storage and, when placed in a secondary container, that container shall be labeled with the words “Pathology Waste,” “PATH,” or other label approved by the department on the lid and sides, so as to be visible from any lateral direction, to ensure treatment of the waste pursuant to Section HSC 118222 (b).

• Can I throw gloves away or is it red bag waste?

  Gloves may go in regular trash so long as they do not have liquid blood dripping off of the or contaminated with any “highly communicable diseases or diseases of animals that are communicable to humans” HSC 117690

• Can you line a sharps container with a red bag?

  No.  “Sharps containers, including those used to containerize trace chemotherapeutic wastes, shall not be lined with a plastic bag or inner liner.” HSC 117750(b)

• Do I have to bleach my liquid biohazardous waste before disposing?

  “Fluid blood or fluid blood products may be discharged to a public sewage system without treatment if its discharge is consistent with waste discharge requirements placed on the public sewage system by the California regional water quality control board with jurisdiction.” HSC 118215(b)  

  Other liquid or semiliquid biohazardous laboratory waste, as defined in HSC 117690 (B)(1)(b), may be treated by a chemical disinfection if the method is recognized by the National Institutes of Health, the Centers for Disease Control and Prevention, or the American Biological Safety Association, and if the use of chemical disinfection as a treatment method is identified in the site’s medical waste management plan.  

  Following treatment by chemical disinfection, the medical waste may be discharged to the public sewage system if the discharge is consistent with waste discharge requirements placed on the public sewage system by the California regional water control board, and the discharge is in compliance with the requirements imposed by the owner or operator of the public sewage system. If the chemical disinfection of the medical waste causes the waste to become a hazardous waste, the waste shall be managed in accordance with the requirements of Chapter 6.5 (commencing with Section 25100) of Division 20. HSC 118215(c)

• Does liquid biohazardous waste have to be reported as an inventory item in CERS?

  Within CERS we are trying to capture the complete picture of the hazardous and medical waste streams generated onsite. For now we are also including liquid biohazardous waste. This may change in the future as we are continuously adjusting our processes to coincide with the information that is collected in CERS.  For now please add a line item for liquid/semi-liquid biohazardous waste. 

• Why is glutaraldehyde waste not reported in CERS and liquid biohazardous waste is (even if they are both ‘approved’ treatments)

  Glutaraldehyde and ortho-phthaldehyde (OPA) are the active ingredients in several brands of sterilizing solutions. Health and Safety Code section 25123.5(c) allows medical facilities to use glycine to neutralize waste glutaraldehyde and OPA disinfectant solutions onsite, without a permit or other authorization prior to disposal to the sanitary sewer. If you prefer to dispose of your wastes rather than treat and dispose onsite, you will still need to characterize the waste as hazardous or non-hazardous.

  The manufacturer of OPA has informed the Department of Toxic Substances Control that the solution at use-dilution fails the California aquatic bioassay toxicity characteristic and thus is hazardous waste when discarded without treatment.  Generators of waste glutaraldehyde who wish to classify the waste as non-hazardous, based on generator knowledge, must be able to show documentation upon which the waste classification was made. This information may be supplied by the vendor or chemical company producing the sterilant.

  Solutions that do not use glutaraldehyde or OPA may or may not be toxic, depending on the cleaning and sterilizing agents used. Check with the manufacturer for guidance.

• How do I manage photowaste (x-ray waste)?

  Photo developer/fixer wastes containing silver or silver compounds are exempt from some hazardous waste requirements if the wastes are properly reclaimed and recycled.  Notification to the hazardous materials division is required through CERS for silver only hazardous waste generators. Contact the duty desk specialist for questions and assistance.

• How do I manage epi-pens?

   Most of the epinephrine used in healthcare facilities consist of epinephrine salts. USEPA has determined that P042 does not include epinephrine salts; therefore, an epinephrine salt is a non-RCRA hazardous waste which at a medical waste generator facility, can also be disposed of a pharmaceutical waste.
  

• How do I conduct a pharmaceutical waste determination?

  Please refer to the Pharmaceutical Waste Guidance document.

• Can I self-transport my medical waste?

    Under the “Materials of Trade Exemption”, A registered/permitted medical waste generator or parent organization that employs health care professionals who generate medical waste may transport medical waste generated in limited quantities up to 35.2 pounds to the central location of accumulation, provided that all of the following are met:

  (1) The principal business of the generator is not to transport or treat regulated medical waste.

  (2) The generator shall adhere to the conditions and requirements set forth in the materials of trade exception, as specified in Section 173.6 of Title 49 of the Code of Federal Regulations.

  (3) A person transporting medical waste pursuant to this section shall provide a form or log to the receiving facility, and the receiving facility shall maintain the form or log for a period of two years, containing all of the following information:

  (A) The name of the person transporting the medical waste.

  (B) The number of containers of medical waste transported.

  (C) The date the medical waste was transported.

• Can my medical waste hauler also haul other types of waste?

  That depends on the hauler.  You need to ask your hauler what types of waste they are permitted to accept. 

• Where can I get copies of my receipts if I don’t have them?

  You will need to contact your medical waste hauler for copies

• What is the importance of labeling containers?

  The reason medical waste containers are required to be labeled is because if the container ends up in the wrong location, the owner of the waste can be quickly identified and contacted for a public health hazard assessment. 

• Can I label the secondary container instead of the primary or both?

  The primary container is required to be labeled; however, you can label both the primary and the secondary if you choose to. 

• Do I still need to secure medical solid waste?

  SDCC. 68.1211 Medical Solid Waste Security was repealed on 07/01/2021.

  Medical solid waste security is still required for treated sharps waste. HSC 118225

  Proper management of treated sharps waste is of particular concern due to the high risk of injury. The California Medical Waste Management Act requires the destruction of sharps that have been rendered non-infectious by treatment if public access to this waste cannot be prevented. If you cannot prevent the public from gaining access to treated sharps waste then you must use other available management practices for treatment and disposal of regulated sharps waste, such as mail-back systems, approved encapsulation technology or a medical waste hauler.

  HSC 118225 - Sharps Waste
  

  (a) Sharps waste shall be rendered noninfectious prior to disposal by one of the following methods:

  (1) Incineration.

  (2) Steam sterilization.

  (3) Disinfection using an alternative treatment method approved by the department.

  (b) Sharps waste rendered noninfectious pursuant to this section may be disposed of as solid waste if the waste is not otherwise hazardous.

  (c) Onsite medical waste treatment facilities treating sharps waste pursuant to paragraph (2) or (3) of subdivision (a) shall ensure that, prior to disposal, the treated sharps waste is destroyed or that public access to the treated sharps waste is prevented. 

• What is the difference between applying for registration versus a temporary event?

  The medical waste temporary event permit was designed for, but not limited to, health fairs, vaccination clinics, and veteran stand downs that are temporarily generating medical waste without further registration or permitting.  This permit is intended for events where medical waste is transported to a permitted/registered central consolidation point for disposal and will not be stored at the location of the temporary permit.  If medical waste will be stored at the event location for 30 days or more, a Registration or Permit is required.

  The medical waste generator shall notify HMD of their intended participation in a temporary event at least 72 hours before the event, unless the sponsor of the temporary event previously notified the HMD of the event.

• How do I notify HMD of MW temporary events?

  Please refer to the Medical Waste Temporary Events Registration Guidance presentation on our website. 

• How do I manage Nicotine?

  The Amendment to the P075 Hazardous Waste Listing for Nicotine Rulemaking was approved by the Office of Administrative Law (OAL) and filed with the Secretary of State on March 9, 2021. The rulemaking removes nicotine patches, gums, and lozenges that are FDA-approved over the counter (OTC) nicotine replacement therapies (NRTs) from the P075 acute hazardous waste listing in California effective on March 9, 2021.

  Management Standards for Hazardous Waste Pharmaceuticals and Amendment to the P075 Listing for Nicotine Rule | Department of Toxic Substances Control

  What does this mean?

  Nicotine ready for disposal which prior to 03/09/2021 would be managed and disposed of as P-listed RCRA HW, are no longer considered P-listed RCRA HW.

  How should Nicotine be managed now?

  If this a pharmaceutical waste, pharmaceutical waste  is not a hazardous waste, and must be managed and disposed of as pharmaceutical medical waste (MW)