Infectious Waste

Regulations imposed by federal and state agencies require that employers develop policies and procedures to address the handling, storage and disposal of infectious materials. On-the-job exposure to bloodborne pathogens and other potentially infectious material is regulated by the Occupational Safety and Health Administration (OSHA) and is addressed through Miami University’s Exposure Control Plan (ECP). The Ohio Environmental Protection Agency (OEPA) regulates those infectious materials that are considered wastes and are destined for treatment and subsequent disposal. This guide focuses largely on the OEPA regulations pertaining to the management and disposal of regulated infectious wastes.

Most infectious waste at Miami University consists of articles that have been contaminated with human blood. However, a significant amount of infectious waste results from teaching and research involving the use of infectious or zoonotic agents. Collectively, Miami University generates infectious waste in excess of fifty pounds per month resulting in the University’s classification as a large quantity generator of infectious waste. Therefore, all facilities owned and operated by Miami University in the State of Ohio must comply with the OEPA infectious waste regulations.

Policy

The EHSO is responsible for coordinating Miami University’s Infectious Waste Management Program. As with chemical waste, individuals who generate infectious waste also retain the primary responsibility for managing their wastes at the point of generation. Individual generators must follow the procedures outlined in this guide to ensure Miami University’s continued compliance with applicable federal and state regulations. All faculty, staff, and students responsible for areas where infectious wastes are generated and/or stored should review this guide periodically.

Program Overview

Miami University maintains multiple Infectious Waste Storage areas at the Oxford campus and a single storage area at both the Middletown and Hamilton campuses. In general, storage locations are maintained as near as possible to the point of generation to minimize the potential for exposure to infectious materials. All storage locations are managed by the department(s) responsible for generating infectious wastes. These locations are inspected periodically by EHSO to ascertain Miami University’s compliance with applicable regulations.

Regulated infectious waste cannot legally be treated via autoclaving and subsequently disposed as normal solid waste on Miami University premises. Therefore, all regulated infectious waste must be treated and disposed off-site at a licensed infectious waste treatment facility. Autoclaves can be used for disinfection and sterilization purposes (i.e., for glassware, equipment) and for the treatment of waste not meeting the OEPA definition of infectious waste. Wastes that do not meet the OEPA definition of infectious waste but require autoclave treatment by another agency (i.e., National Institute of Health) must be autoclaved in bags not labeled with the international biohazard symbol.

Regulated Infectious Waste

The first step towards proper Infectious Waste Management is to determine whether a waste is regulated. In general, waste materials are considered infectious if they have been potentially exposed to infectious or zoonotic agents. The following OEPA definitions are taken from Ohio Administrative Code (OAC) Chapter 3745:

  • Infectious Agent - a type of microorganism, pathogen, virus or prion that can cause or significantly contribute to the disease in or death of human beings.
  • Zoonotic Agent - a type of microorganism, pathogen, virus or prion that causes disease in vertebrate animals, is transmissible to human beings and can cause or significantly contribute to the disease in or death of human beings.

Please refer to the Categories of Infectious Waste for further guidance in determining whether a waste is regulated, or contact EHSO (9-2829) for assistance.

Generator Requirements

Generators of regulated infectious wastes must comply with the following:

  • Segregate infectious waste from other waste at the point of generation.
  • Ensure that all infectious wastes are transferred to an approved storage location for subsequent off-site treatment and disposal (contact EHSO at 9-2829 for the nearest storage location).
  • All sharps infectious waste (i.e., hypodermic needles and syringes, scalpel blades, broken glass exposed to infectious agents) must be collected in containers specifically designed and manufactured for the management and/or disposal of sharps. These containers should be labeled with the international biohazard symbol and the word SHARPS. All sharps infectious waste must be transferred to an approved storage location for subsequent off-site treatment and disposal.
  • Liquid cultures of infectious waste (biosafety levels 1 and 2) may be chemically treated using a 15% household bleach solution. The culture must remain in contact with the bleach solution for a minimum of twenty minutes. After treatment, liquid cultures can be released to the sanitary sewer.
  • Untreated liquid or semi-liquid infectious waste consisting of blood, blood products, body fluids, and excreta, may be disposed into the sanitary sewer system without prior treatment.
  • In the event of an accidental spill or release of infectious waste, the person(s) responsible for the spill must initiate containment and cleanup. The Infectious Waste Spill Containment and Cleanup Procedure must be followed when responding to an infectious waste spill. All personnel must periodically review and become familiar with this procedure.

Storage Location Requirements

All Infectious Waste Storage locations must be established and approved by EHSO. Infectious Waste Storage locations must comply with the following:

  1. Infectious waste, other than liquid infectious waste, must be accumulated in boxes supplied by the infectious waste disposal contractor. These boxes meet all transport requirements specified by the OEPA and Department of Transportation (DOT). The following restrictions apply when using these boxes:
    1. All waste must be bagged or properly containerized before being placed in a box.
    2. No liquids shall be placed in a box without prior approval from EHSO. Certain exceptions apply for limited quantities (i.e., < 30 mL) of liquids when packaged properly.
    3. Absolutely no chemically hazardous or radioactive waste, regardless of its infectious nature, shall be disposed of in a box.
    4. Do not fill a box beyond its maximum weight capacity. The maximum capacity of a large box (4.3 cu. ft.) is 50 pounds and a small box (1.9 cu. ft.) is 30 pounds.
  2. Infectious Waste Storage locations must be marked at all points of access with the international biohazard symbol. At a minimum, these locations must be secured and limited to authorized personnel.
  3. Establish a pickup schedule (i.e., weekly, monthly, quarterly) with the infectious waste disposal contractor that will allow for timely removal of infectious waste from the storage location.
  4. All Infectious Waste Manifests (or shipping/disposal receipts) arising from shipments of Infectious Waste are to be sent to EHSO immediately.
  5. The Infectious Waste Spill Containment and Cleanup Procedure must be posted at each Infectious Waste Storage location. In the event of a spill, the person(s) responsible for the storage area must initiate the containment and cleanup procedure.

By following the procedures outlined in this guide you can help to ensure that Miami University remains in compliance with the OEPA Infectious Waste Regulations. Please contact EHSO with any questions or suggestions for improving the Infectious Waste Management Program.