Managing sharps and other medical waste in the non-healthcare business setting has been an issue for years. On-site medical clinics bear little difference from off-site doctors’ offices and therefore face similar management issues regarding used syringes, expired medications and body fluid cleanup. Yet today, self-injection of prescription medications outside of healthcare facilities to treat such diseases as diabetes, allergies, hepatitis and other medical conditions generates over three billion sharps each year…most of which are thrown into the trash. Providing safe containment and proper disposal for all sharps, as well as other biohazardous waste, is more important today than ever.

Step 1: Identification

The first step in proper medical waste management is to define medical waste and identify where it is generated within the facility. The most dangerous medical waste is, of course, “sharps.” Sharps include hypodermic and suture needles, lancets, blood-contaminated glass, box-cutter blades and any other sharp object contaminated with blood.

Besides sharps, OSHA defines regulated medical waste as items saturated with blood and other potentially infectious material (OPIM.) OPIM consists of fluids such as semen, vaginal secretions and any body fluid that is visibly contaminated with blood.

The most typical settings where sharps and other medical wastes are found in the business or industrial setting are medical clinics, employee restrooms, cafeteria, warehouse and mailroom.

Step 2: Containment

After defining medical waste and identifying where it could be generated or found, it is crucial to properly contain the waste by establishing handling procedures, training employees and implementing proper containment systems. OSHA requires that sharps containers be located as close as possible to where sharps could be found or generated, and that spill kits are available.

The onsite medical clinic should be equipped with sharps containers in each exam and procedure room. If proper waste segregation is being practiced (see Waste Segregation Chart), most clinics will not need red bags. One container/bag for non-sharps waste is typically placed in the procedure room.

Unused or expired medications that are non-hazardous and non-controlled may be contained as regulated medical waste in most situations.

A vandal-resistant sharps containment system in the employee restroom can provide self–injecting employees a safe, confidential point-of-generation disposal method. In the cafeteria, a biohazard cleanup and disposal kit should be located in the food preparation area where cuts and other injuries might occur. In addition, a body fluid spill cleanup kit should be maintained in the cafeteria.

In the warehouse and mailroom, cleanup kits containing EPA-registered disinfectants, personal protective and cleanup equipment, and sharps containers should be available.

Step 3: Disposal

Facilities choose different methods for disposing of sharps and other medical waste based on existing service in their areas, disposal costs and familiarity with options.

Option 1: Contract with a medical waste pickup service — Ideal for large-quantity generators of medical waste such as hospitals and labs.
Option 2: Take medical waste to a healthcare provider — This presents potential liability for both the facility and the healthcare provider who agrees to dispose of the medical waste, as waste from the two sources becomes commingled. In addition, transporting sharps to a healthcare facility may not comply with state regulations.
Option 3: Disposing of sharps in the regular trash ? — Any facility with one or more employees is covered by OSHA or its state's bloodborne pathogen standard. These standards require sharps to be safely contained in puncture-resistant, labeled containers designed for sharps. These containers must then be properly disposed. Throwing sharps containers into the trash is not permitted by most state medical waste regulatory agencies. Furthermore, sharps containers are not designed to be compacted. If a container breaks open during compaction in a garbage truck, waste handlers can be exposed to its contents. In fact, the EPA no longer recommends disposal of needles in the trash even for home users, whether at home, work or another location; and regardless of whether the sharps are placed in a container first.
Option 4: Dispose of sharps and medical waste by mail — Created specifically for small-quantity generators, this EPA-recommended mail system is transported by the United States Postal Service.

Step 4: Training & documentation

Businesses should provide employees OSHA bloodborne pathogen training, DOT generator training and state-specific medical waste management training. Annual refresher training is required. Generators of medical waste have a cradle-to-grave responsibility for the waste they generate. Consequently, it is important to track waste through final destruction. Proving sharps have been properly disposed may not only be required, it is good risk management as well.