Handle with Care: Key Takeaways on Special Pathogen Waste Management
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Proper waste management is crucial when caring for patients infected with or suspected of being infected with a special pathogen. The NETEC webinar, “Handle with Care: Special Pathogen Waste Management,” provided valuable insights from industry experts on best practices, compliance requirements, and effective coordination for managing infectious waste. Here are the top lessons learned:
1. Understanding Regulatory Requirements
Managing special pathogen waste involves multiple regulatory agencies, including the Occupational Safety and Health Administration (OSHA), the Department of Transportation (DOT)/Pipeline and Hazardous Materials Safety Administration (PHMSA), and the Environmental Protection Agency (EPA). Key takeaways include:
- DOT Classification: Infectious substances fall under Class 6.2 hazardous materials, further categorized as Category A (high risk) or Category B (lower risk).
- Special Permits: Handling Category A waste requires a special permit, such as DOT Special Permit 16279 for Ebola, Lassa fever, and Marburg virus.
- State and Local Regulations: While federal regulations set the baseline, state, local, tribal, or territorial (SLTT) requirements may also apply, making compliance coordination essential.
2. Do’s and Don’ts of Waste Handling
| Do’s of Waste Management | Don’ts of Waste Management |
| Do keep waste from a suspect case separated from general waste. | Don’t label waste as Category A until confirmatory testing is completed. |
| Do minimize what may become Category A waste by removing unnecessary supplies or packaging before entering the patient care space. | Don’t treat durable items that can be safely and effectively decontaminated as waste, i.e., mattresses, furniture, or equipment. |
| Do double-bag and securely close waste at its point of origin. | Don’t overfill bags or attempt to compress waste in bags. |
| Do engage internal and external partners (infection prevention, public health, EVS, waste vendor) when developing Category A waste management plans. | Don’t forget to notify partners as soon as a suspect case is identified. |
| Do reach out to your Regional Emerging Special Pathogen Treatment Center (RESPTC) for assistance. | Don’t wait until you have a case of a suspected or confirmed special pathogen in your facility! Plan now. |
3. The Importance of Planning and Preparedness
A well-defined waste management plan reduces risks and ensures compliance. Key elements include:
- Partner Coordination: Hospitals must collaborate with waste vendors, emergency services, infection prevention teams, and their local public health authorities.
- Storage & Sequestering: Facilities should have designated spaces for securing waste, especially for patients suspected of being infected with a special pathogen before confirmed diagnosis.
- Regular Training & Drills: Conducting mock exercises and educating staff on handling procedures enhance safety and preparedness.
- Written Plans: Procedures on the operationalization of waste packaging, storage, and coordination are important to be recorded in emergency operating plans for future reference.
4. Effective Packaging and Transportation
- Category A waste must be packaged in DOT-compliant PG2 containers with double-liner bags and absorbent material.
- Waste containers should be clearly labeled and disinfected before transport.
- Partner with vendors that have the necessary permits and facilities to handle special pathogen waste.
5. Communication and Training Are Key
Ensuring staff understand their roles in waste management is critical. Best practices include:
- Communicating with your waste vendor on the safe handling of hazardous or bulky items such as batteries, sharps boxes, and mattresses.
- Providing role-specific training for clinicians, environmental services, and waste handlers, including appropriate personal protective equipment (PPE).
- Establishing clear protocols for waste storage, pickup, and emergency spill response.
- Keeping up-to-date with industry changes, such as revisions to special permits and new waste treatment technologies.
Final Thoughts
Effective waste management for special pathogens is a team effort requiring strategic planning, compliance with evolving regulations, and continuous education. By following best practices in waste classification, packaging, transport, and training, healthcare facilities can ensure the safe and efficient disposal of hazardous materials while protecting public health.
For further resources, refer to the Inter-Agency Guidance on Special Pathogen Waste Management and consult with your waste disposal partners to align on compliant processes.
Watch the webinar or take the free online course for continuing education credit!
About the Experts
Caroline Croyle Persson, MPH, MPA, CIC, PMP, FAPIC, is the Program Director for Disaster Health Denver Health. Her work focuses on healthcare emergency management, coordination and collaboration, and capacity building to enhance healthcare preparedness and response efforts. Prior to her current role, Mrs. Persson worked in infection prevention and control with a focus on influenza, emergency management, high risk pathogens, program and policy management, hand hygiene, and regulatory compliance. She has worked on various public health projects prior to arriving at Denver Health spanning malaria prevention, community health worker sustainment, emergency management, and HIV/AIDs mobile health application acceptance. Mrs. Persson has an MPH from Columbia University with a certificate in Infectious Disease Epidemiology and an MPA from the University of Colorado Denver.
Alex Chapman is Director of Regulatory Affairs for Stericycle with 20 years of experience working with healthcare, commercial, and government organizations. Her work has included developing, managing, and supporting programs that drive regulatory compliance and sustainability as well as performance improvement, enablement, and education initiatives. While she has worked in a number of roles and industries, Alex’s work has primarily been in complex regulated environments with a focus on healthcare collaborating with generators, suppliers, industry organizations, and regulators to reduce risk and enhance compliant and sustainable management of waste throughout the value chain. Alex is the membership and special projects coordinator for the Healthcare Waste Institute, co-president of the Stericycle Green Team, and chairs Stericycle’s Women’s ERG, WRISE. Alex is driven to help individuals and organizations reach their goals and create safe and sustainable environments for themselves, their employees, and the communities they serve.
Jill Morgan, RN, is a nurse at Emory University Hospital. She has been on Emory’s biocontainment team for over 15 years where she has cared for patients with Ebola virus disease and Lassa fever. Jill is co-lead for the PPE working group for NETEC, the National Emerging Special Pathogens Training and Education Center and has recently been appointed to the National Academies Committee on Personal Protective Equipment and Workplace Safety and Health.
Cara Simaga, CHMM, is Sr. Director of Regulatory Affairs at Stericycle. In her role she supports the business in ensuring program and service offerings are compliant. She will celebrate 15 years with Stericycle this November and has prior experience in the hazardous waste industry. Cara was chairperson of the Healthcare Waste Institute for 3 years (2020, 2021, 2022) and is currently the regulatory liaison.
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