EIA: Disposal Diagnosis

By Alice P. Jacobsohn

As the healthcare industry has changed, so must environmental management companies that provide the industry with waste management services. A couple of years ago, the National Solid Wastes Management Association and the Waste Equipment Technology Association reformed their policy-making group on regulated medical waste (RMW) and infectious substances to create the Healthcare Waste Institute (HWI). HWI has a broader interest in that members are involved in pharmaceutical waste management, medical device reconditioning, animal carcass and other veterinary waste disposal, dental waste services, education and training of environmental service coordinators, and the transport and disposal of RMW and infectious substances. Members include healthcare waste management consultants, equipment and product manufacturers, and distributors.

HWI members have recognized that a single company cannot be effective operating on its own. Small companies may not have the capability to hire employees dedicated to tracking changes in the law. Even large companies with employees dedicated to compliance may find they need industry support to accomplish their goals. Despite fierce competition, a seat at the table of a trade association ensures that a company’s voice is heard, guarantees that relevant information is analyzed and distributed quickly creating a potential market advantage, provides a community network for sharing business knowledge and, perhaps most importantly, offers a social setting in which industry leaders can associate with like-minded people.

HWI will tackle a range of activities, including dealing with company-specific and industry-wide issues with the support of industry members and staff, developing guidance documents and educating members about various regulations, advocating before legislators and regulators on issues key to industry operations, and building relationships with medical waste generators.

Recently, HWI has been working on a number of critical industry issues. In May 2010, the U.S. Occupational Safety and Health Administration (OSHA) issued two requests. The first was for information on the risks of exposure to infectious diseases in healthcare-related settings. The second was for a regulatory review of the Bloodborne Pathogens Standard. In both instances, OSHA is looking to improve occupational safety regulations. HWI submitted written comments on the pathogens standard. At the end of July, members and staff participated in a meeting on waste issues associated with infectious diseases.

HWI is in the process of developing a position statement on pharmaceutical waste management, particularly in commercial settings, to address several efforts at the federal level to prevent abuse. The U.S. Environmental Protection Agency is working on guidance to prevent disposal of these wastes down drains. The Drug Enforcement Administration is developing regulations to prevent the diversion of controlled substances meant for long-term care facilities and other end users.

At the annual Healthcare Waste Conference held in Dallas in May, HWI members facilitated a number of educational sessions on regulatory changes and common compliance myths. The conference also included an interactive workshop on transportation issues that served as a means for attendees to develop a dialogue on gaps and conflicts in the regulations.

Alice P. Jacobsohn is director of the Healthcare Waste Institute. She also is director for education at NSWMA-WASTEC, responsible for the development of the annual Healthcare Waste Conference.